REGULATIONSCONFLICT MINERALS

Conflict Minerals

This binds only EU importers of 3TG as raw minerals or metals above the annex volume thresholds — roughly 600 to 1,000 importers. If you manufacture finished products, it does not bind you either.

FALLS ONCONFIRMS ON BUYER INVITATION

Neither of you is legally bound here. You ask because your own customers ask you.

THE OFFICIAL ARTIFACT

What the supplier must actually produce.

Not a policy statement. The industry template, completed at smelter level, that your buyer carries into their own reporting.

WHO SIGNS IT OFF
Where it does apply, the importer maintains the due-diligence system, undergoes independent third-party audit, and publishes an annual report.
REQUIRED ARTIFACT · CONFLICT MINERALS6 ELEMENTS
Conflict Minerals Reporting Template (CMRT)
REG. (EU) 2017/821 · ART. 4–7 · OECD DUE DILIGENCE GUIDANCE
Smelters and refinersNamed, per metal, with facility identifiers.
Country of originOf the minerals, as far up the chain as it is known.
Product scopeWhich of your parts or products the declaration covers.
Sourcing policyWhether one exists, and where it is published.
Chain-of-custody responsesThe template’s standard question set, completed.
Update cadenceRefreshed at least annually, or when sourcing changes.
THE CHARACTERISTIC FAILURE

A sourcing policy arrives instead of a template.

A CMRT arrives, or does not. Either way no statute compelled it.

WHAT USUALLY ARRIVESINSUFFICIENT
Responsible sourcing policy
CORPORATE POLICY · SIGNED BY MANAGEMENT · PUBLISHED
A genuine commitment, properly governed
States principles, not facilities
No smelter names, no country of origin
NOT SUFFICIENT
A policy is not a chain. The importer must identify smelters and refiners, and a statement of intent does not do that.
WHAT THE REGULATION NAMESSUFFICIENT
Completed CMRT
SMELTER LEVEL · PER METAL · ANNUAL REFRESH
Every smelter and refiner named, per metal
Country of origin recorded where known
Scoped to the products the buyer actually purchases
SUFFICIENT
Same sourcing, same suppliers — reported at the level the importer’s obligation actually needs.
THE DELTA: A STATEMENT OF PRINCIPLES VS NAMED SMELTERS AND REFINERS
NEXT MILESTONE · CONFLICT MIN.
LAST VERIFIED 9 AUG 2026
OnINVITATION
ON INVITATIONNO STANDALONE DEADLINE
Confirmed on buyer invitation

The duty sits with the EU importer. You enter this only when a buyer invites you — Mappliance then holds the smelter and origin evidence they need.

Does CONFLICT MINERALS reach your products?

Find out whether this reaches you at all before you cascade it down.

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