EU Conflict Minerals Regulation term for union importer.
Union importer belongs to the EU conflict-minerals due-diligence framework. It should be tied to mineral scope, importer role, smelter/refiner position, conflict-affected or high-risk area context, and OECD-aligned due-diligence evidence rather than treated as a generic sustainability label.
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
any natural or legal person declaring minerals or metals for release for free circulation within the meaning of Article 201 of Regulation (EU) No 952/2013 of the European Parliament and of the Council or any natural or legal person on whose behalf such declaration is made, as indicated in data elements 3/15 and 3/16 in accordance with Annex B to Commission Delegated Regulation (EU) 2015/2446
Article 2 definitions for EU conflict-minerals due diligence. Source-specific to tin, tantalum, tungsten, their ores, and gold.
Reference: Article 2, point (l)
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.