The EU passed a Regulation on Conflict Minerals ("the Regulation") back in 2017 and its requirements will finally begin to apply to importers of covered minerals as of 1 January 2021. Conflict minerals – usually "the 3Ts" (tantalum, tin, and tungsten) and gold ("3TG") are crucial in the components of many consumer electronic products and have applications in aerospace, automotive, medical and other sectors. The mining of these elements has been linked to the advancement of armed conflict and human rights abuses, particularly in the Democratic Republic of Congo and the Great Lakes region of Africa. The Regulation requires EU importers to conduct robust due diligence in their supply chains in order to cut off the flow of finance to the mines controlled by rebel groups committing these abuses.
The EU began its controversial legislative process on conflict minerals back in 2013, following on from the introduction of US rules requiring listed companies to disclose the use of conflict minerals under the Dodd-Frank Act (the "US Rules"). With such a long lead-in to the mandatory requirements, some businesses will have already considered whether they fall within the rules, and made appropriate adjustments to their compliance programmes. Others will understandably have addressed more pressing business needs and now need to consider what action, if any, they need to take ahead of the 1 January 2021 compliance deadline.