On 25th October, an article on Mondo Visione reported that the LME has announced its responsible sourcing requirements following a formal market-wide consultation on proposals underpinned by the OECD Due Diligence Guidance.  The LME requirements, which will apply to all its listed brands, rest on 4 core principles:

  • the combination of transparency and standards;
  • non-discrimination between large-scale mining (LSM) and artisanal / small-scale mining (ASM);
  • adherence to well-established work in the sector; and
  • a pragmatic and clear process.

While still using the OECD 5-step framework for risk-based due diligence in the mineral supply chain, the LME will now provide 3 “tracks” to achieve compliance:

  • producers (whether or not they exhibit red flags) who wish to follow an industry scheme may adopt an internal or external OECD-aligned standard (“track A”);
  • producers that raise no red flags in their initial assessment may complete a LME RFA standard-form template – which can then either be externally audited (“track B”); or
  • reviewed and then published by the LME (“track C”).

The LME has provided reasonable timelines for compliance, with full engagement required by 2022 and full compliance by 2023.

This blog is primarily for my own use, to keep informed and up to date. However, if you would like to say thank you (and perhaps help me get a new, better laptop when I am away…) you can “buy me a coffee” 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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