Conflict Minerals

Under U.S. Dodd-Frank Act Section 1502 and SEC Rule 13p-1, 'adjoining countries' are the nations that share a border with the Democratic Republic of the Congo (DRC) and are included in the definition of 'Covered Countries' subject to conflict minerals disclosure requirements. These countries are: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

The Additional Minerals Reporting Template (AMRT), formerly known as the Pilot Reporting Template (PRT), is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) for collecting due diligence information on minerals not covered by the CMRT (3TG) or EMRT (cobalt, copper, graphite, lithium, mica, nickel). The AMRT allows input for up to ten user-specified minerals. AMRT version 1.31 was released on April 17, 2026; the next version is anticipated in Fall 2026.

Under the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, 'armed groups' are defined as groups distinct from government or state military forces that use violence to pursue political or economic goals, including seizure or taxation of mineral extraction, transport, or trade. Identifying and avoiding the financing of armed groups is a core objective of both the U.S. Dodd-Frank Section 1502 and EU Conflict Minerals Regulation (EU) 2017/821.

Artisanal and Small-Scale Mining (ASM) refers to informal or semi-formal mining activities conducted by individuals or small groups with limited mechanization, often operating in developing countries. ASM is a significant source of 3TG minerals, particularly gold, tin, tantalum, and tungsten in the DRC and adjoining countries. ASM operations are associated with higher conflict mineral risk because they frequently operate in conflict-affected areas and may be subject to control or taxation by armed groups.

Battery minerals due diligence refers to the supply chain transparency and risk management obligations applicable to minerals used in battery manufacturing, including cobalt, lithium, graphite (natural), nickel, copper, and manganese. While not classified as 3TG conflict minerals under Dodd-Frank, these minerals are subject to growing due diligence requirements under the EU Battery Regulation (EU) 2023/1542, emerging ESG frameworks, and customer-driven reporting via the EMRT and AMRT templates.

A Conflict-Affected and High-Risk Area (CAHRA) is a region characterized by armed conflict, widespread violence, weak governance, or systematic violations of international law, in which the extraction and trade of minerals may contribute to or be linked to these conditions. The OECD Due Diligence Guidance defines CAHRAs as the geographic areas where due diligence obligations are most critical. The EU Commission maintains an indicative, non-exhaustive list of CAHRAs under Regulation (EU) 2017/821, most recently updated through procurement under EC-TRADE/2025/OP/0006.

Chain of custody in conflict minerals refers to the documented sequence of entities — from mine to smelter/refiner to downstream manufacturer — through which a mineral passes, with records at each transfer point establishing provenance and responsible sourcing status. A robust chain of custody allows downstream companies to trace whether minerals originated from conflict-affected areas and whether each transfer point exercised responsible sourcing practices.

The Conflict Minerals Reporting Template (CMRT) is a free, standardized reporting template developed by the Responsible Minerals Initiative (RMI) for exchanging due diligence information on tin, tantalum, tungsten, and gold (3TG) across supply chains. It facilitates identification of smelters and refiners used, country of origin data, and compliance status. CMRT version 6.6 is the current version, released April 17, 2026, introducing two new Product List fields: Requester Product Number and Requester Product Name. The next version is anticipated in Spring 2027.

Coltan is the informal name for columbite-tantalite, a metallic ore from which tantalum is extracted. Coltan is listed by name in Dodd-Frank Section 1502 as one of the conflict mineral ores. The DRC is one of the world’s largest coltan producers, and eastern DRC coltan mining has been directly linked to funding armed groups. Coltan is processed at tantalum refiners/processors, which are audited under RMAP for responsible sourcing.

Competent authorities under Regulation (EU) 2017/821 are the Member State authorities designated to receive conflict minerals due diligence documentation, conduct checks, and enforce the regulation. Article 10 of the Regulation requires each Member State to designate one or more competent authorities. In Germany, the competent authority is the Federal Office of Economics and Export Control (BAFA); in France, it is the Customs and Excise Authority. Competent authorities have the power to request documentation, conduct audits, and apply sanctions for non-compliance.

Conflict minerals are minerals whose extraction and trade in conflict-affected areas finances armed groups or contributes to human rights abuses. Under U.S. Dodd-Frank Section 1502, conflict minerals are defined as columbite-tantalite (coltan, the ore of tantalum), cassiterite (the ore of tin), gold, wolframite (the ore of tungsten), and their derivatives, specifically tantalum, tin, tungsten, and gold (collectively known as 3TG). The EU Conflict Minerals Regulation (EU) 2017/821 covers the same four minerals and their ores.

A Conflict Minerals Report (CMR) is a document filed by SEC registrants as an exhibit to Form SD when their RCOI and due diligence determine that conflict minerals may have originated in the DRC or adjoining countries and are not from recycled or scrap sources. The CMR must describe the due diligence measures taken, including the framework used (e.g., OECD Due Diligence Guidance), the facilities used to process the conflict minerals, the country of origin of the minerals, and efforts to determine mine or location of origin.

The term ‘DRC conflict-free’ was defined under the original SEC conflict minerals rules as minerals that did not directly or indirectly finance or benefit armed groups in the DRC or adjoining countries. However, following a 2014 U.S. Court of Appeals decision (National Association of Manufacturers v. SEC), SEC guidance states that companies should not be required to describe their products as ‘DRC conflict-free,’ ‘not DRC conflict-free,’ or ‘DRC conflict undeterminable’ in the Conflict Minerals Report. Instead, companies describe their due diligence efforts and findings.

A conformant smelter or refiner is a smelter or refiner facility that has completed an audit under the Responsible Minerals Assurance Process (RMAP) or another recognized due diligence scheme and has been found to meet all applicable requirements. Conformant status means the facility has demonstrated that its sourcing practices do not fund armed groups in conflict-affected areas. RMAP maintains a publicly available list of conformant, active, and eligible facilities by metal.

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (enacted July 21, 2010) is the U.S. legislative provision requiring SEC-registered issuers that manufacture or contract to manufacture products containing tin, tantalum, tungsten, or gold (3TG) — where such minerals are necessary to the product’s functionality or production — to disclose annually whether those minerals originated in the DRC or adjoining countries. Section 1502 added Section 13(p) to the Securities Exchange Act of 1934 and directed the SEC to promulgate implementing rules.

The Democratic Republic of the Congo (DRC) is the primary geographic focus of global conflict minerals regulation. The DRC is rich in 3TG minerals and has experienced decades of armed conflict in which mineral revenues have funded armed groups. Under U.S. Dodd-Frank Section 1502 and SEC Rule 13p-1, the DRC is the central ‘covered country.’ Under EU Regulation (EU) 2017/821, the DRC is a primary conflict-affected and high-risk area. Both frameworks aim to prevent minerals extracted in the DRC from financing armed conflict.

Due diligence in the context of conflict minerals refers to the ongoing process of risk identification, assessment, and management that companies must apply to their mineral supply chains to ensure minerals do not originate from sources that fund armed conflict or contribute to human rights violations. The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016) is the internationally recognized framework aligned with both Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821.

The Extended Minerals Reporting Template (EMRT) is a free, standardized reporting template developed by RMI for collecting due diligence information on cobalt, copper, graphite (natural), lithium, mica, and nickel — minerals not covered by the CMRT but increasingly subject to regulatory and customer-driven due diligence requirements. EMRT version 2.11 was released April 17, 2026. Key changes include IPC-1755-compatible enhancements, updated ISO country abbreviations, correction of a Declaration tab date input issue, and refreshed Smelter Reference and Standard Smelter Lists. The next EMRT version is anticipated in Spring 2027.

ESG (Environmental, Social, and Governance) frameworks increasingly incorporate conflict minerals due diligence as a social and governance disclosure expectation, independent of legal requirements. Institutional investors, sustainability ratings agencies (e.g., MSCI, Sustainalytics), and industry frameworks such as the Global Reporting Initiative (GRI 408/409 on child and forced labour, GRI 3 on material topics) reference responsible mineral sourcing as a social risk metric. Companies not subject to Dodd-Frank or EU Regulation may still face conflict minerals disclosure expectations from investors and customers through ESG channels.

Regulation (EU) 2017/821 of the European Parliament and of the Council, dated 17 May 2017, lays down supply chain due diligence obligations for Union importers of tin, tantalum, tungsten, their ores, and gold originating from conflict-affected and high-risk areas (CAHRAs). The Regulation entered into full force on 1 January 2021. It applies to EU importers above volume thresholds set in Annex I, ensuring that no less than 95% of total volumes imported into the EU of each mineral is subject to obligations. On October 16, 2025, the European Commission formally recognized RMAP as equivalent to the Regulation’s requirements via Implementing Decision (EU) 2025/2071.

The five-step OECD framework is the internationally recognized due diligence process for responsible mineral sourcing from conflict-affected and high-risk areas, established in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016). The five steps are: (1) Establish strong company management systems; (2) Identify and assess risks in the supply chain; (3) Design and implement a strategy to respond to identified risks; (4) Carry out independent third-party audit of supply chain due diligence at identified checkpoints; (5) Report annually on supply chain due diligence.

Form SD is the SEC disclosure form under which SEC-registered companies file their annual conflict minerals disclosures. Required by Exchange Act Section 13(p) and Rule 13p-1 (implementing Dodd-Frank Section 1502), Form SD must be filed annually by May 31 for the prior calendar year. Form SD requires companies to disclose: whether conflict minerals are necessary to the functionality or production of their products, the results of their Reasonable Country of Origin Inquiry (RCOI), and — if applicable — a Conflict Minerals Report describing due diligence measures.

Gold (Au) is one of the four 3TG conflict minerals under Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821. Gold is extracted from ores and is used in electronics (contacts, connectors), jewellery, dental applications, and financial products. Gold presents the most complex conflict minerals traceability challenge among 3TG minerals because it is fungible, traded globally in standardized forms, and a significant source of ASM revenues in the DRC and adjoining countries. Gold refiners are the pinch point for gold supply chain due diligence.

An Independent Private Sector Audit (IPSA) is a third-party audit of a company’s Conflict Minerals Report (CMR) conducted by an independent, qualified audit firm. The original SEC conflict minerals rule required issuers to obtain an IPSA of their CMR. However, the SEC Division of Corporation Finance issued staff guidance in 2017 stating that it would not recommend enforcement action if companies did not obtain the IPSA. This de facto suspension of IPSA enforcement has remained in place; however, the Form SD filing requirement has continued.

IPC-1755 is the international data exchange standard that governs how conflict minerals information is structured, formatted, and transmitted between supply chain partners. Developed by IPC (Association Connecting Electronics Industries), IPC-1755 enables machine-readable and automated exchange of CMRT and EMRT data between companies and compliance platforms. Both the CMRT and EMRT are designed to align with IPC-1755. CMRT 6.6 includes enhancements that remain fully compatible with IPC-1755.

The ITSCI (ITRI Tin Supply Chain Initiative) Programme is a supply chain transparency and traceability scheme for 3TG minerals — particularly tin, tantalum, and tungsten — operating in artisanal mining regions of Central Africa, including the DRC, Rwanda, and Burundi. ITSCI implements a bagging and tagging system at mining sites to track mineral origin from mine to export, and includes an incident reporting system to identify and address human rights and security incidents. ITSCI membership is widely used by smelters as evidence of responsible upstream sourcing for RMAP audits.

Under SEC Rule 13p-1 implementing Dodd-Frank Section 1502, a ‘manufacturer’ is a company that (1) manufactures a product or (2) contracts to manufacture a product. A company is considered to ‘contract to manufacture’ if it has some actual influence over the manufacturing of the product. The SEC has stated that a company that merely affixes its label to a generic product or negotiates basic product specifications (such as color or size) may not be considered to contract to manufacture for conflict minerals purposes.

Mine of origin refers to the specific mining location from which a mineral was extracted. In conflict minerals frameworks, identifying the mine of origin is the ultimate objective of supply chain traceability, as it allows companies to determine whether minerals came from conflict-affected areas and whether the mining operation exercised responsible practices. However, for most 3TG minerals, traceability beyond the smelter/refiner to the mine level is not yet achievable at scale. The OECD Due Diligence Guidance calls on companies to make ‘reasonable efforts’ to identify mine of origin.

Under SEC Rule 13p-1, a conflict mineral is ‘necessary to the functionality or production’ of a product when it is intentionally included in the product and either (a) necessary for the product to function as intended (‘necessary to functionality’) or (b) required in the production process that creates the product (‘necessary to production’). Conflict minerals that are incidentally present in the product or that are contained in common materials (such as off-the-shelf components) where the manufacturer had no influence over their inclusion may not be considered ‘necessary.’

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd Edition, 2016) is the primary international framework for conflict minerals supply chain due diligence. It provides a five-step due diligence process applicable to all companies in the mineral supply chain. It includes a general guidance chapter applicable to all minerals and metal-specific supplements for gold (Supplement on Gold), tin, tantalum, and tungsten (Supplement on Tin, Tantalum and Tungsten). Both the U.S. Dodd-Frank/SEC rule and EU Regulation (EU) 2017/821 are aligned with this guidance.

In conflict minerals supply chains, the ‘pinch point’ is the point in the supply chain where all upstream ore flows converge before being transformed into a metal product that cannot be traced back to its original source. For 3TG minerals, the smelter or refiner is the pinch point. Once ore is smelted into metal, individual origin traceability is effectively lost. This is why conflict minerals due diligence frameworks focus audit activity at the smelter/refiner level rather than requiring each downstream manufacturer to trace minerals to the mine level.

Public reporting in conflict minerals refers to the obligation for companies to publicly disclose their conflict minerals due diligence activities, findings, and smelter data on an annual basis. For U.S. SEC registrants, this is accomplished through Form SD and the attached Conflict Minerals Report, both publicly filed with the SEC via EDGAR and posted on the company website. Under EU Regulation (EU) 2017/821, Article 9 requires Union importers to make their supply chain due diligence policies and practices publicly available on the internet on an annual basis.

A Reasonable Country of Origin Inquiry (RCOI) is the initial due diligence step required of SEC registrants under Dodd-Frank Section 1502. An RCOI is a good-faith inquiry into whether a company’s conflict minerals originated in the DRC or adjoining countries. The RCOI uses supplier declarations (typically CMRT data) to establish likely country of origin. If the RCOI reasonably determines that minerals did not originate from covered countries, or originated from scrap/recycled sources, a Conflict Minerals Report may not be required.

Under Dodd-Frank Section 1502 and SEC Rule 13p-1, conflict minerals from recycled or scrap materials are exempt from the requirement to conduct supply chain due diligence beyond reasonable inquiry. ‘Recycled minerals’ are reclaimed end-user or post-consumer products, or scrap processed metals created during product manufacturing. If a company’s RCOI determines that all conflict minerals in its products come from recycled or scrap sources, it can state this in its Form SD without filing a Conflict Minerals Report.

Requester Product Number and Requester Product Name are two new fields added to the Product List tab of CMRT version 6.6 (released April 17, 2026). These fields allow the requesting company (typically a manufacturer or OEM) to pre-populate their own internal product identifiers directly within the template before sending it to suppliers. This enables suppliers to complete the CMRT with the requester’s product reference already embedded, facilitating more accurate matching of supplier declarations to specific products in the requester’s internal systems.

Risk assessment in conflict minerals due diligence refers to the systematic process of identifying and evaluating whether the supply chain is contributing to or at risk of contributing to armed conflict, human rights abuses, money laundering, or other OECD Annex II risks. Risk assessment is Step 2 of the OECD five-step framework. It involves evaluating smelter-level data (country of origin, RMAP status), supplier-level data (CMRT responses, response rates), and geographic-level data (CAHRA proximity) to prioritize risk mitigation efforts.

The Responsible Minerals Assurance Process (RMAP) is the third-party audit program operated by RMI to verify that smelters and refiners of tin, tantalum, tungsten, and gold have systems in place to ensure responsible sourcing from conflict-affected and high-risk areas. RMAP audits assess whether smelters can demonstrate that their mineral inputs do not finance armed groups. Smelters that pass an RMAP audit are classified as ‘conformant.’ On October 16, 2025, the European Commission formally recognized RMAP as equivalent to EU Conflict Minerals Regulation (EU) 2017/821 requirements via Implementing Decision (EU) 2025/2071.

The Responsible Minerals Initiative (RMI) is an initiative of the Responsible Business Alliance (RBA) that provides companies with tools, resources, and audit programs to support responsible mineral sourcing from conflict-affected and high-risk areas. RMI owns and maintains the CMRT, EMRT, and AMRT reporting templates, operates the Responsible Minerals Assurance Process (RMAP) audit program, and maintains the smelter conformant/active/eligible facility lists. RMI was formerly known as the Conflict Free Sourcing Initiative (CFSI).

The U.S. Securities and Exchange Commission (SEC) is the federal regulatory body that administers and enforces the conflict minerals disclosure requirements under Dodd-Frank Section 1502 through Rule 13p-1 and Form SD. The SEC adopted the final Conflict Minerals Rule on August 22, 2012, with reporting beginning for the 2013 calendar year. Form SD filings are submitted to the SEC’s EDGAR system by May 31 annually. In 2025, SEC Commissioner Mark Uyeda publicly questioned the effectiveness and cost burden of the rule, signaling potential policy debate, though the rule remains in force as of April 2026.

A smelter or refiner is the facility that processes raw 3TG mineral ores into metal products. In conflict minerals supply chains, smelters and refiners are the ‘pinch point’ — the last stage where mineral origin can be verified before transformation makes individual source traceability impossible. The four mineral types have specific smelting processes: tin smelters process cassiterite ore, tantalum processors convert coltan into tantalum powder, tungsten smelters process wolframite/scheelite, and gold refiners process gold doré or scrap. RMAP audits are conducted at the smelter/refiner level.

The Standard Smelter List is the reference list embedded within each CMRT version that identifies smelters and refiners of 3TG minerals and their current RMAP audit status (conformant, active, or listed). It is maintained and updated by RMI with each CMRT release. The Standard Smelter List in CMRT 6.6 (released April 17, 2026) reflects the most current RMI-validated data. Suppliers completing CMRTs cross-reference their smelter entries against this list. Manufacturers use it to verify the RMAP status of identified smelters.

Supplier engagement in conflict minerals compliance refers to the proactive outreach and communication program by which companies collect CMRT data from their suppliers, address non-responses, and work with suppliers to improve smelter RMAP participation. Supplier engagement is both a data collection mechanism (CMRT request campaigns) and a risk mitigation tool (engaging suppliers whose smelters are non-conformant to encourage RMAP participation). Effective supplier engagement is a key element of OECD Step 3 (risk response) and Step 1 (management systems).

A supply chain policy for conflict minerals is a formal, publicly communicated statement of a company’s commitment to responsible mineral sourcing and its expectations of supply chain partners. It is required as Step 1 of the OECD five-step due diligence framework and is expected by the EU Conflict Minerals Regulation and Dodd-Frank. The policy should clearly state the company’s stance on conflict minerals, expectations for suppliers, and the consequences of non-compliance.

Tantalum (Ta) is one of the four 3TG conflict minerals, primarily extracted from coltan ore (columbite-tantalite). Tantalum is used in capacitors found in smartphones, laptops, game consoles, and other electronics; in medical implants; and in aerospace applications. A significant portion of the world’s tantalum comes from the DRC and neighboring Rwanda and Burundi, making it a high-priority mineral for conflict minerals compliance. Tantalum refiners/processors are audited under RMAP for responsible sourcing practices.

Tin (Sn) is one of the four 3TG conflict minerals, extracted from cassiterite ore. Tin is used primarily as a solder in electronics manufacturing (circuit boards, component assembly), in tin plating, and in alloys. Tin is the highest-volume 3TG mineral used in electronics. Significant sources of tin include the DRC, Indonesia, and Myanmar. The DRC is a notable conflict-risk source, particularly from eastern provinces. Tin smelters are audited under RMAP for responsible sourcing.

Traceability in conflict minerals refers to the ability to identify and document the chain of custody of a mineral from its point of extraction (mine) through processing, smelting, and refinement to the point of use in a finished product. Complete traceability would allow a downstream manufacturer to verify that a specific batch of metal in its product came from a specific, identified, responsible mine. In practice, full traceability is rarely achievable for 3TG minerals due to mineral fungibility and supply chain complexity; smelter-level traceability is the practical standard.

Tungsten (W) is one of the four 3TG conflict minerals, extracted primarily from wolframite and scheelite ores. Tungsten is used in electronics (vibration motors in mobile phones, hard drive components), cutting tools, light bulb filaments, military applications (ammunition), and jewelry. Significant sources include China (largest global producer), DRC, and Rwanda. Tungsten is one of the less-publicized 3TG minerals but remains subject to full conflict minerals due diligence requirements under both Dodd-Frank and EU Regulation (EU) 2017/821.

A Union importer under Regulation (EU) 2017/821 is any natural or legal person established in the EU who declares minerals or metals containing or consisting of tin, tantalum, tungsten, or gold for release for free circulation into the EU. Union importers above the volume thresholds specified in Annex I of the Regulation are subject to mandatory supply chain due diligence obligations. The regulation applies to importers of both raw minerals/ores and semi-processed or processed metals at specified Combined Nomenclature (CN) codes.

Volume thresholds under Regulation (EU) 2017/821 are the minimum annual import volumes of 3TG minerals or metals below which Union importers are exempt from mandatory due diligence obligations. Thresholds are set in Annex I at a level that ensures at least 95% of total import volumes for each mineral and metal under its Combined Nomenclature (CN) code is covered. For example: tin ores and concentrates threshold is 6,000 kg/year; for gold in unwrought form the threshold is 100 kg/year. Thresholds vary by CN code and mineral type.

3TG is the collective abbreviation for the four minerals designated as conflict minerals under U.S. Dodd-Frank Section 1502 and EU Regulation (EU) 2017/821: Tin, Tantalum, Tungsten, and Gold. These four minerals and their ores (cassiterite for tin, coltan for tantalum, wolframite/scheelite for tungsten, gold doré for gold) are the scope of all conflict minerals reporting obligations under the CMRT, Form SD, and EU Regulation.