The European Union regulates the import of tungsten, tin, tantalum, or their ores, or gold (3TG)

Importers of tungsten, tin, tantalum, or their ores, or gold (the "3TGs") must pay particular attention to their origin.

These minerals, commonly known as "Conflict Minerals" and found in our cell phones, cars or jewellery, can be controlled by armed groups and be the source of armed conflict, human rights violations and forced child labour.

To prevent this, in May 2017, the European Union adopted the European Regulation 2017/821, which sets obligations related to supply chain due diligence for importers of minerals from conflict or high-risk areas into the European Union.

This regulation aims to regulate the extraction of minerals in certain areas (Democratic Republic of Congo and the Great Lakes region of Africa, Burma, Latin America)

The goals of this regulation are

• to ensure the traceability of 3TG flows

• to ensure the responsible management of 3TG sources

• to enable the creation of secure, transparent, and verifiable supply chains

• to ensure, facilitate and promote the responsible import of minerals and metals from conflict or high-risk areas into the EU without contributing to armed conflict or associated human rights abuses, in a manner that contributes to the economic development and livelihoods of local communities.

This European regulation defines principles of Social Responsibility for companies so that they, as well as their suppliers, are aware of the impacts of their activities on the outside world and put in place a strategy to deal with the risks identified in order to prevent or mitigate them.

It applies to upstream companies but also concerns those downstream since they can now require proof of traceability of their raw materials. This makes the CMRT an essential tool for the global conformity of minerals from conflict zones.

The Conflict Minerals Reporting Template (CMRT) is used to evaluate 3TG suppliers. It is a standardised tool from the Responsible Minerals Initiative (RMI) that facilitates sharing of information between different supply chain actors.

Using this tool, SFA Group's procurement team reached out to its suppliers and collected so-called CMRT reports for global compliance of minerals from conflict zones. 

The regulation came into force on January 1, 2021, in a bid to regulate supply chains and force transparency from the various players.