On 29th October, Squire Paton Boggs LLP published its EU Conflict Minerals Regulation Flowchart, a companion to its earlier one covering the US conflict minerals regulations.  It explains that the EU adopted its conflict minerals Regulation in 2017, targeting the trade in tin, tantalum, tungsten, and gold and linked to adverse impacts in conflict-affected or high-risk areas around the world.  The due diligence and disclosure obligations of the EU Regulation commence on January 1st 2021. However, it says, there will be consequences to having even indirect relationships with non-conformant smelters and refiners.  So, the article says, it is wise to analyse your supply chains before the obligations take effect and then actively manage your supply chain relationships to reduce the costs of compliance and to minimize any negative impacts on your business.  Like the US conflict minerals rule flowchart it also makes available, the firm’s EU conflict minerals regulation flowchart is intended to allow conflict minerals teams to work through the concepts of the Regulation to make quick references to relevant provisions of the Regulation.

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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