Laying down supply chain due diligence obligations for conflict minerals

20170314PHT66772_originalThe European Parliament recently approved its version of the “conflict minerals rule.”  The EU rule will go into effect on January 1, 2021, once it has been approved by the EU Council.

This regulation would require all but the smallest of EU importers of “conflict minerals” to conduct mandatory due diligence of their suppliers.  Some of the differences between the EU rule and the U.S. rule are:

  • Downstream manufacturers, importers and sellers of finished goods would not be required to conduct due diligence.
  • Applies to all conflict-affected and high-risk regions in the world, not just the DRC.
  • Companies can become a “responsible importer” by declaring they follow the due diligence requirements.
  • Each EU member country will be responsible for ensuring compliance and determining non-compliance penalties.

Link to the legislation can be found here.