Traceability

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.

OECD Due Diligence Guidance, Third Edition (2016); Regulation (EU) 2017/821; RMAP audit standards.

Traceability is a spectrum. For most downstream manufacturers, the practical achievable level is smelter-country-of-origin traceability — knowing which smelters processed the mineral and from which countries the ore was sourced. Full mine-level traceability is achievable only in specific regions with established upstream certification (e.g., ITSCI in Rwanda/DRC). Companies should maximize traceability within the bounds of what is practically achievable and document efforts to improve traceability over time.

An OEM’s traceability program achieves: 100% of smelters identified (smelter traceability), 85% of smelters can identify country of origin (country traceability), and 15% of smelters can identify specific mines of origin (mine traceability) due to ITSCI certification coverage. The OEM sets annual targets to improve mine-level traceability.