On 12th April, Squire Patton Boggs published a briefing that says that while many companies are working to complete their due diligence and prepare conflict minerals disclosure for their SEC filings in the US due on May 31st, others are considering whether they will be subject to the EU Conflict Minerals Regulation when its due diligence and disclosure obligations take effect on 1st January 2021.  It notes that the EU Regulation makes it easy for companies to determine whether they are covered by the Regulation – they need only review their EU Customs Declarations against Annex I of the Regulation.  The law firm says it will issue an interactive EU Conflict Minerals flowchart guide shortly.

Meanwhile, the firm’s US Conflict Minerals flowchart is available at –

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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