The EU conflict minerals regime
Produced in partnership with Dynda Thomas and Simon Garbett of Squire Patton Boggs
The EU conflict minerals regime

The following Commercial guidance note Produced in partnership with Dynda Thomas and Simon Garbett of Squire Patton Boggs provides comprehensive and up to date legal information covering:

  • The EU conflict minerals regime
  • Background
  • Commercial considerations
  • First steps for practitioners
  • Who is covered?
  • Which metals and minerals are covered?
  • Which geographies are covered?
  • Which due diligence framework applies?
  • What must EU importers do?
  • What is still not settled?
  • more

Brexit: As of exit day (11pm on 31 January 2020) the UK is no longer an EU Member State. However, in accordance with the Withdrawal Agreement, the UK has entered an implementation period, during which it continues to be subject to EU law. This has an impact on this Practice Note. For further guidance, see Brexit Bulletin—key updates, research tips and resources and Brexit toolkit.


Responsible sourcing is now an important dimension to supply chain management. Supply chain professionals must account for and respond to non-governmental organizations (NGOs), customers, shareholders, and regulators’ expectations that business entities should know the provenance of all materials and components in their products, and that they should address the human rights impacts of their operations and supply chains. Sourcing valuable minerals from conflict-affected and high-risk areas is one of the most challenging supply-chain concerns.

To address that concern, in 2010, the US Congress included a provision in the Dodd-Frank Act Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) that required the Securities and Exchange Commission (SEC) to issue a rule focused on breaking the connection between trade in certain minerals sourced in central Africa and extreme human rights violations by armed groups there. The SECs conflict minerals rule was adopted in 2012 and requires US reporting companies to disclose the use, source and