15th December 2020
The new EU conflict minerals regulation comes into force on 1st January 2021. For EU importers of conflict minerals (upstream industry) extensive due diligence and inspection obligations along the supply chain are binding. This includes tin, tantalum, tungsten, their ores and gold from conflict and high-risk areas if they exceed a certain imported quantity. For the further processing industry (downstream industry) no binding regulations are provided, i.e. the producers and importers of end products. However, the downstream industry is asked to exercise voluntary due diligence.
We assume that there will be specific inquiries within the supply chain in the future. In order to be prepared for this, we have developed non-binding sample formulations that you can download here as a pdf.
The text passages can be used individually for company-specific replies. It is also possible to use the document as a whole in communication. Of course inquiries must be answered truthfully. The explanations given in the sample formulations must be adapted or changed accordingly. No liability is accepted for correctness and completeness.