EU Conflict Minerals Regulation

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.

Regulation (EU) 2017/821 of the European Parliament and of the Council, 17 May 2017; Implementing Decision (EU) 2025/2071 (October 16, 2025); EUR-Lex.

The EU Regulation is structurally different from U.S. Dodd-Frank: it applies to importers of raw minerals and metals (not downstream manufacturers), and it requires active due diligence rather than just disclosure. EU importers must: adopt a supply chain policy, identify and assess risks in their supply chain, design and implement risk management strategies, submit their supply chain due diligence policies, practices, and measures to competent authorities, and report publicly. The RMAP recognition (October 2025) means EU importers who source through RMAP-conformant smelters can use this as evidence of compliance.

A German electronics components company imports 2,500 kg/year of tantalum metal from a processor in China. This exceeds the Annex I threshold. The company must implement the OECD five-step due diligence process, obtain CMRT data from the processor, verify RMAP conformance, and report annually to the German competent authority (Federal Office of Economics and Export Control, BAFA).