Glossary term

recycled metals

EU Conflict Minerals Regulation term for reclaimed end-user/post-consumer or scrap processed metals suitable for recycling into 3TG metals.

1 official sourceSingle-source term

What does recycled metals mean?

Recycled metals are a source-status and material-output concept. They need evidence of reclaimed/post-consumer or scrap processed metal status and must not be used for partially processed minerals, unprocessed minerals, or by-products from another ore.

Source context

North America critical-minerals context: U.S. sources use designation/list logic under 30 U.S.C. § 1606 and the Federal Register 2022 list; Canada Income Tax Act section 127.49 uses qualifying material and qualifying mineral activity for a tax-credit context. Keep these source layers separate from EU CRMA critical/strategic raw material and EU conflict-minerals definitions.

Official definitions by source

EU Conflict Minerals

Regulation (EU) 2017/821 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas

reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing, including excess, obsolete, defective, and scrap metal materials which contain refined or processed metals that are appropriate for recycling in the production of tin, tantalum, tungsten or gold. For the purposes of this definition, minerals partially processed, unprocessed or a by-product from another ore are not considered to be recycled metals

Article 2 definitions for EU conflict-minerals due diligence. Source-specific to tin, tantalum, tungsten, their ores, and gold.

Reference: Article 2, point (s)

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Practical application

Implementation records should capture mineral or metal scope, actor role, source location, conflict-affected/high-risk area assessment, chain-of-custody or traceability record, due-diligence scheme or policy, risk-management decision, audit/disclosure evidence, and relevant OECD Guidance link where applicable.

Minespider commentary

For Minespider, conflict-minerals terms should route sourcing claims into auditable objects: mineral/material scope, importer declaration, smelter/refiner identity, custody sequence, area-risk classification, due-diligence policy, grievance/risk records, and recycled-metal or by-product evidence where relevant.

Common confusions

  • Treating conflict-minerals terms as generic ESG due-diligence language outside tin, tantalum, tungsten, ores, and gold scope.
  • Collapsing Union importer, smelter/refiner, and downstream product actors into one responsibility role.
  • Using chain-of-custody or traceability labels without sequence-of-custody and economic-operator evidence.

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