We are pleased to announce the launch of our EU Conflict Minerals Regulation Flowchart, which promises to be a valuable tool for those charged with compliance with the EU conflict minerals regulation.
In 2017, the EU adopted its conflict minerals regulation, which is intended to help businesses identify and address the risk that 3TGs (tin, tantalum, tungsten, and gold) in their products are 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 1, 2021. However, there will be consequences to having even indirect relationships with non-conformant smelters and refiners. So, it is wise to analyze 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.
Those who will be responsible for conflict minerals compliance can prepare by watching some of the scores of free, on-demand webinars that are available online, or by reading any of the hundreds of law firm client alerts on the subject. But, ultimately, you will have to focus on the particulars of the regulation itself. Our EU Conflict Minerals Regulation Flowchart puts the EU regulation at your fingertips – it organizes the regulation by topic, provides a general discussion of each topic and then provides quick links to the relevant provisions in the regulation. It also provides a comparison of how each of the requirements of the EU regulation applies to imports of minerals versus imports of metals.
We invite you to download the EU Conflict Minerals Regulation Flowchart and use the diagram on page 1 as your starting point. Then, use the links to access the relevant provisions or work through the outline page by page. You may choose links that take you directly to the EU conflict minerals regulation, which is presented as it appears in the Official Journal of the European Union and is fully searchable. The flowchart and the regulation are housed together to allow you to navigate freely between them.
We developed the EU Conflict Minerals Regulation Flowchart as a companion to the US Conflict Minerals Rule Flowchart that we released in 2012. The US flowchart is still useful today – providing big picture guidance, definitions and discussions of elements of the regulation, and providing links to the SEC conflict minerals release and FAQ responses. The US flowchart was widely recognized when it was released as a helpful resource to in-house conflict minerals teams (including in-house lawyers).
And, to make it easy for you to find the flowcharts in the future, we’ve added them to the Resources tab at the top of the blog, and we’ve added two download buttons in the right hand menu on the blog page.