No matter what industry category your products fall under, you’ll likely find requirements to report conflict minerals. While conflict minerals reporting requirements have been in place for years now, the conversation around what minerals should be included and how they should be reported has been changing as social awareness of conflict affected regions grows.
If you are new to conflict minerals reporting requirements, how do you get started? And what minerals do you need to report? Here is a basic primer to help you understand the ins and outs of conflict minerals reporting.
What Are Conflict Minerals?
The traditionally reported conflict minerals are known as 3TG—tin, tantalum, tungsten, and gold. These are considered conflict minerals because they are often sourced from areas with political instability and where their sale can contribute to violence and human rights abuses. The Democratic Republic of Congo has traditionally been the geographical example used for where the sourcing of minerals can contribute to conflict, but conflict minerals can be found in other countries as well.
Conflict minerals are found in products consumers use every day, notably in electronics like cell phones, computers, and cars. This means that if you produce products, especially in electronics, you will likely need to report the use of conflict minerals.
Conflict Minerals Regulations
In the United States (US), conflict minerals are regulated under the Dodd-Frank Wall Street Reform and Consumer Protection Act, which was passed in 2010. Section 1502 of this act requires that publicly traded companies disclose the use of 3TG in their products and the source of those minerals. The idea is that increased transparency in the use of conflict minerals will encourage companies to find more ethically responsible sourcing options.
In 2021, the European Union (EU) enacted their new Conflict Minerals Regulation. This regulation not only requires conflict mineral use to be reported, but also requires EU importers to meet responsible sourcing standards from the Organisation for Economic Co-operation and Development (OECD).
Minerals Beyond 3TG
While 3TG have traditionally been the focus of conflict minerals regulations, recent concern over other minerals has increased the scope of conflict minerals reporting for many companies.
There is growing concern about sourcing cobalt and mica, as these minerals have often been sourced from areas using child labor and/or human trafficking. While legislation does not yet require cobalt and mica reporting, we may see it required in the future.
We are also seeing many companies wanting to get ahead of this possibility and maintain ethical sourcing before it becomes an issue. Many are already requiring their suppliers to report on cobalt and mica. As concern for other minerals grows in the future, we may see more conflict minerals added to this list as well.
Reporting Conflict Minerals
In past years, the most common way to report conflict minerals was to use the Conflict Minerals Reporting Template (CMRT) developed by the Responsible Minerals Initiative (RMI) to facilitate reporting. This tool helped users to identify and report mineral sources.
Since the scope of conflict minerals has extended recently, RMI has developed a new tool: the Extended Minerals Reporting Template (EMRT). This template allows companies to report minerals beyond 3TG like cobalt and mica, with room to expand in the future should more conflict minerals be added to regulation and requirement lists.
Using the EMRT is not a requirement for reporting conflict minerals. Rather, it is a tool meant to facilitate easier reporting no matter what agency you are required to report to.
If you need help understanding your conflict minerals requirements, using the EMRT, or surveying your supply chain, contact Tetra Tech’s experts at [email protected]. We can help you develop a conflict minerals reporting program that works efficiently to meet requirements, train staff, and help you meet regulations with confidence.