On 8 April, an article from NAVEX Global says that this Regulation came into force on 1 January and aims to ensure that importers of certain materials originating from conflict-affected and high-risk areas source these materials responsibly by laying down supply chain due diligence obligations. It says that, although some EU-based companies have already developed conflict minerals due diligence schemes, either as a result of voluntary efforts or due to obligations arising from activities in the US, the current legislative developments reflect the need to enhance these efforts and address evolving ESG challenges. The EU Regulation directly applies to upstream and downstream companies when they import the targeted minerals or metals into the EU. Indirectly, companies from outside of the EU will also be impacted. The article provides a summary of the Regulation and its requirements. It explains that the term ‘conflict minerals’ commonly refers to tin, tantalum, tungsten and gold (the “3TGs”), as covered by the EU regulation. 3TGs are widely used in the electronics, automotive, medical devices, tooling, and aerospace industries, often ending up in everyday products including cars, mobile phones, laptops, and jewellery. Multinationals can knowingly or sometimes unknowingly be affected by having them in their supply chains.
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