Regulation (EU) 2017/821 · applicable since 1 January 2021
Four metals that sit inside almost every electronic product.
Tin, tantalum, tungsten and gold finance armed groups in some regions. The EU therefore requires importers to run documented due diligence down to the smelter.
The regulation binds Union importers of ores and metals containing 3TG above certain volume thresholds. It requires a due diligence system along the five steps of the OECD guidance: management system, risk identification, risk mitigation, independent audit and reporting.
Swiss companies are rarely in the direct scope – but the Swiss twin applies: the Code of Obligations sets its own conflict minerals duties with their own thresholds. And as a supplier to an EU importer you will be asked about the smelter regardless.
Who is affected
- Union importers of 3TG ores and metals above the annex thresholds.
- Swiss companies through the Code of Obligations duties, with their own thresholds and exemptions.
- Makers of electronics, tools, fasteners and jewellery – through customer requests.
- Trading tiers that import nothing but must pass origin data on.
The five steps
- Management system
- A supply chain policy, clear ownership and a traceability system.
- Identify risks
- Establish origin down to the smelter or refiner and assess risks.
- Mitigate risks
- An action plan, reporting to management, and where needed ending the relationship.
- Independent audit
- Third-party audit of the due diligence system.
- Report
- Annual public reporting on due diligence.
How SCRM covers it
Chain down to the smelter
Supplier, upstream supplier and smelter as linked records, not attachments.
Collect declarations
Request the common industry reporting templates digitally and attribute the answers.
Versioned risk assessment
The trail shows what was known when – the heart of any due diligence.
Audit preparation
Documents for the independent audit are already sorted.
Frequently asked
We buy finished components. Are we affected?
Usually not as an importer under the regulation. Your customer still asks, because they must report – and their answer depends on data from you.
Why the smelter specifically?
The smelter or refiner is the last point at which a metal’s origin can still be determined. After that the material is mixed.
Are there recognised programmes?
Yes, industry-wide audit and reporting programmes for smelters exist. They help considerably but do not replace your own assessment.
As of July 2026. Not legal advice.