Mine of Origin

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.

OECD Due Diligence Guidance, Third Edition (2016), Step 3; Dodd-Frank Act Section 1502(b)(2)(B); SEC Rule 13p-1.

Mine of origin identification is an aspirational standard in the Conflict Minerals Report. The SEC acknowledges that mine-level traceability is often not possible for downstream companies. The Conflict Minerals Report must describe ‘efforts to determine the mine or location of origin.’ In practice, most companies can only identify country-level origin through CMRT data, with mine-level data available only where upstream certification programs like ITSCI are operating.

A gold refiner participating in RMAP is required to trace gold inputs to the mine or ASM cooperative level where possible. Using GPS-coded mine documentation from ITSCI-covered areas in Rwanda, the refiner can identify 35% of its gold by specific mine. The remaining 65% is traced only to country of origin (Rwanda). Both levels of data are recorded in the RMAP audit report.