Volume Threshold (EU Conflict Minerals Regulation)

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.

Regulation (EU) 2017/821, Article 1(3) and Annex I.

Volume thresholds are the first compliance filter for EU importers. Companies must calculate their annual import volumes per CN code and compare against Annex I thresholds. If below all thresholds, no mandatory due diligence obligations apply under the EU Regulation — though voluntary due diligence and customer requirements may still apply. If above any threshold, the full five-step OECD due diligence process applies for that mineral/metal. Note that the gold threshold (100 kg/year) is low enough to capture many mid-size importers.

A Swiss trading company imports 80 kg/year of gold in unwrought form — below the 100 kg Annex I threshold. It is exempt from mandatory EU Conflict Minerals Regulation due diligence obligations for this gold. However, if it also imports 8,000 kg/year of tin ores (above the 6,000 kg threshold), it must comply with the regulation for tin.