EU Conflict Minerals Regulation obligations for Union importers to manage, audit, disclose, and address risks linked to conflict-affected and high-risk areas.
Supply chain due diligence is an obligation system, not a general statement that a supplier was checked. It needs importer responsibility, material scope, risk assessment, management response, audit, and disclosure evidence.
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
the obligations of Union importers of tin, tantalum and tungsten, their ores, and gold in relation to their management systems, risk management, independent third-party audits and disclosure of information with a view to identifying and addressing actual and potential risks linked to conflict-affected and high-risk areas to prevent or mitigate adverse impacts associated with their sourcing activities
Article 2 definitions for EU conflict-minerals due diligence. Source-specific to tin, tantalum, tungsten, their ores, and gold.
Reference: Article 2, point (d)
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.
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.