Procurement Glossary
Conflict Minerals: Definition, compliance requirements and implementation in Procurement
November 19, 2025
Conflict minerals are raw materials from conflict areas whose extraction and trade finance armed conflicts or promote human rights violations. These minerals - mainly tin, tantalum, tungsten and gold - present purchasing organizations with complex compliance challenges. Find out below what conflict minerals are, what legal obligations exist and how you can make your supply chain transparent and responsible.
Key Facts
- Conflict Minerals comprises the four main minerals tin, tantalum, tungsten and gold (3TG)
- US and EU regulations oblige companies to disclose and conduct due diligence
- The main mining areas are in the Democratic Republic of the Congo and neighboring countries
- The sectors affected are electronics, automotive, jewelry and medical technology
- Compliance requires full supply chain traceability all the way to the mine
Contents
What are Conflict Minerals?
Conflict minerals are raw materials whose extraction and trade in conflict areas contribute to the financing of armed groups or cause serious human rights violations.
The four main minerals (3TG)
The regulations focus on four critical minerals:
- Tin (Tin): Used in solder and electronic components
- Tantalum: capacitors in smartphones and computers
- Tungsten (Tungsten): Tungsten carbide tools and filaments
- Gold: Electronic contacts and jewelry
Conflict minerals vs. critical raw materials
While critical raw materials are primarily concerned with security of supply, conflict minerals focus on ethical and social aspects. The overlaps require integrated procurement strategies that take into account both availability and compliance requirements.
Importance of Conflict Minerals in Procurement
Purchasing organizations must check and document their entire supply chain for conflict minerals. This requires close cooperation with suppliers, comprehensive due diligence processes and transparent reporting to stakeholders and regulatory authorities.
Implementation, obligations and evidence
Compliance with Conflict Minerals regulations requires systematic processes to identify, assess and document the origin of minerals throughout the supply chain.
Reasonable Country of Origin Inquiry (RCOI)
Companies must first determine whether their products contain Conflict Minerals and could originate from affected regions. This initial assessment includes:
- Product analysis and material composition
- Supplier survey using standardized forms
- Risk assessment according to geographical criteria
Conflict Minerals Due Diligence
If the RCOI result is positive, comprehensive due diligence is required. The process follows the OECD guidelines and includes supplier audits, proof of origin and continuous monitoring of the supply chain.
Reporting and documentation
Listed US companies must file Form SD with the SEC annually. EU importers require certificates of compliance and must document their due diligence obligations. The reports contain detailed information on smelters, refineries and countries of origin.
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Compliance KPIs & evidence for Conflict Minerals
Effective Conflict Minerals programs require measurable metrics to monitor compliance performance and continuously improve due diligence processes.
Supply chain coverage and traceability
Central KPIs include the proportion of suppliers with complete CMRT (Conflict Minerals Reporting Template) documentation and traceability back to the smelter. Target values are 100% coverage for critical suppliers and at least 95% of identified smelters and refineries.
Audit and validation metrics
The quality of due diligence is measured by the following indicators:
- Proportion of smelters audited by recognized programs (RMI, LBMA)
- Average response time for supplier inquiries
- Number of compliance deviations identified and remedied
Cost-benefit analysis
Compliance costs are compared with the risks avoided. Typical metrics are compliance costs per product unit, ROI of due diligence investments and costs saved through early risk identification. KYC processes support the systematic evaluation.
Risks, dependencies and countermeasures
Non-compliance with Conflict Minerals regulations poses significant legal, financial and reputational risks for companies and their supply chains.
Compliance and legal risks
Violations of Conflict Minerals regulations can lead to SEC sanctions, EU fines and trading restrictions. Incomplete or inaccurate reporting jeopardizes listing and can result in civil lawsuits from investors.
Supply chain disruptions
Dependence on a small number of conflict-free sources significantly increases supply risks. Political instability in alternative mining areas can lead to price volatility and supply bottlenecks. Companies must develop diversified procurement strategies and implement supplier codes.
Reputational and market risks
Negative media coverage of Conflict Minerals in the supply chain can cause significant reputational damage. Consumers and B2B customers are increasingly demanding transparent and ethical sourcing. Whistleblowing systems and proactive communication are essential for risk management.
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Practical example
A German automotive supplier implements a comprehensive Conflict Minerals program for its electronic components. The company first carries out an RCOI analysis for all products and identifies 150 suppliers with potential 3TG materials. Using standardized CMRT forms, origin data is collected and 85% of the melts are successfully identified. On-site audits are carried out for critical suppliers and alternative procurement sources are qualified.
- Implementation of a digital tracking system for seamless documentation
- Training of 50 purchasers on conflict minerals compliance
- Establishment of an escalation process for non-compliance cases
Current developments and effects
The regulatory landscape for Conflict Minerals continues to evolve, with more stringent requirements and expanded applications on a global scale.
Extension of the EU Conflict Minerals Regulation
Since 2021, the EU regulation has covered all importers of the four minerals above certain thresholds. Future extensions could include further minerals and downstream companies, which would significantly expand the compliance requirements for German purchasing organizations.
Digitalization and blockchain technology
Innovative technologies are revolutionizing the traceability of Conflict Minerals. Blockchain-based systems enable seamless documentation from mining to the end product, while AI-supported analyses automate risk assessments and improve the traceability of materials.
Integration in ESG frameworks
Conflict minerals are increasingly being integrated into comprehensive ESG assessments. Rating agencies such as EcoVadis consider Conflict Minerals compliance as a key sustainability indicator, which has a direct influence on financing conditions and business relationships.
Conclusion
Conflict minerals compliance has become indispensable for modern purchasing organizations and requires systematic due diligence processes along the entire supply chain. Regulatory requirements are continually tightening, while innovative technologies are creating new opportunities for transparent traceability. Successful programs combine robust compliance structures with proactive supplier management and contribute to both risk minimization and sustainable value creation.
FAQ
Which companies are affected by Conflict Minerals regulations?
Listed US companies that manufacture products with 3TG minerals and EU importers above the thresholds (tin: 1t, tantalum: 1t, tungsten: 1t, gold: 100kg per year) must meet compliance requirements. Downstream companies are also indirectly affected by supplier requirements.
How does "conflict-free" differ from "DRC conflict-free"?
"DRC conflict-free" refers specifically to minerals that do not contribute to the financing of armed groups in the Democratic Republic of Congo. "Conflict-free" is a broader term that can also include other conflict areas and human rights violations.
What are the costs of Conflict Minerals compliance?
Typical costs include due diligence processes (€50,000-200,000 per year), supplier audits (€5,000-15,000 per audit), IT systems for tracking (€20,000-100,000) and external consulting. The total costs vary considerably depending on the complexity of the supply chain and product portfolio.
How can traceability back to the mine be ensured?
Complete traceability requires multi-level approaches: Supplier mapping, melt identification through CMRT forms, third-party audits of recognized programs and increasingly blockchain-based tracking systems. 100% traceability remains a challenge due to complex supply chains.
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