EU Conflict Minerals Regulation
The EU Conflict Minerals Regulation (CMR) aims to prevent the trade of minerals that finance armed conflict or human rights abuses. It focuses on four key minerals: tin, tantalum, tungsten, and gold (3TG).
The regulation is built on the OECD Due Diligence Guidance, a five-step framework for responsible sourcing across the entire mineral supply chain, from mining to manufacturing.
The regulation applies to EU importers that exceed specific thresholds:
- 4,000,000 kg of gold ores and concentrates
- 100 kg of unrefined or semi-manufactured gold
- 100 kg of refined gold (≥99.5% purity)
Small-volume importers and companies dealing only with recycled metals are exempt.
Why is it important?
Responsible sourcing is essential for:
- Preventing links to armed conflict
- Upholding human rights
- Building trust in the precious metals industry
The 100kg threshold for gold imports laid out in the current rules risks weakening standards for responsible sourcing, leading to reputational consequences for industry.
All EPMF members have committed to stringent voluntary schemes for responsible sourcing which go beyond the requirements laid out in the CMR.
While the CMR targets upstream importers, we also encourage downstream users to report on supply chain due diligence in line with EU non-financial reporting guidelines.
The EPMF supports a more ambitious EU Regulation on conflict minerals, which would be applicable to all imports of gold and require more in-depth involvement of the full supply chain. More specifically, the EU CMR should:
- Remove the gold threshold include all imports in the scope of the regulation.
- Clearly define “high-risk” and “conflict-affected area”.
- Involve the entire gold supply chain.
The EPMF believes that addressing conflict minerals must be a coordinated effort between all stakeholders involved, from local governments to private companies, industry experts and NGOs.
