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Conflict Minerals (3TG) Compliance

Tin, tantalum, tungsten, and gold — collectively known as 3TG — are present in nearly every electronic product, from the solder on circuit boards to the capacitors in power supplies, from the tungsten vibration motors in smartphones to the gold contact pads in connectors.

But these four metals have a dark side. In certain regions — most notably the Democratic Republic of Congo (DRC) and adjoining countries — the extraction and trade of 3TG minerals has financed armed conflict, enabled forced labor, and caused severe human rights abuses. In response, legislators in the United States and the European Union have created mandatory supply chain due diligence regimes designed to break the link between mineral extraction and conflict financing.

If your product contains tin, tantalum, tungsten, or gold — and if your company is publicly traded in the US or imports these minerals into the EU — you have legal obligations to trace your supply chain, assess risks, and publicly report your findings.

The Two Regulatory Frameworks

US: Dodd-Frank Section 1502

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010) requires publicly traded companies in the United States to conduct a "reasonable country of origin inquiry" (RCOI) into whether the 3TG minerals in their products originated in the DRC or adjoining countries.

If the minerals did (or might have) originated from that region, the company must conduct supply chain due diligence, file a Conflict Minerals Report (CMR) with the SEC, and disclose whether any of its products are "DRC conflict free" or "not found to be DRC conflict free."

Key points for SMEs: - The direct filing obligation applies only to SEC-registered companies. - However, publicly traded customers will demand 3TG sourcing data from their entire supply chain — including non-public SME suppliers. - The SEC rule does not require companies to stop sourcing from the DRC region; it only requires them to disclose the source and due diligence undertaken.

EU: Conflict Minerals Regulation (Regulation [EU] 2017/821)

The EU Conflict Minerals Regulation, which entered into full application in January 2021, applies to EU-based importers of tin, tantalum, tungsten, and gold in their raw mineral or metal form — not to importers of finished products containing these metals.

Key points: - The direct obligation applies to EU importers of 3TG ores and metals above defined volume thresholds. - Unlike the US rule, the EU Regulation does not apply to manufacturers of finished products (though this may change in future reviews). - EU importers in scope must conduct mandatory supply chain due diligence aligned with the OECD Due Diligence Guidance for Responsible Supply Chains.

Despite the narrower direct scope, the EU Regulation has a powerful indirect effect: like the US rule, it drives data requests down the supply chain. Even companies not directly regulated must provide 3TG sourcing information to their customers who are.

The Four Metals: Where Are They in Your Products?

Metal Common Industrial Applications
Tin (Sn) Solder on printed circuit boards, tin plating on connectors and component leads, bearing alloys
Tantalum (Ta) Tantalum capacitors (ubiquitous in electronics), sputtering targets for semiconductors, medical implants
Tungsten (W) Vibration motors in smartphones, wear-resistant cutting tools, electrical contacts, lighting filaments
Gold (Au) Contact pads on PCBs, connector plating, bonding wires in integrated circuits, corrosion-resistant coatings

If your product contains any electronics — even a simple LED driver with a PCB — it almost certainly contains tin (in the solder), and likely contains tantalum (in capacitors) and gold (on contact surfaces).

The Responsible Minerals Initiative (RMI) and Standardized Reporting

The industry has coalesced around a common tool to manage conflict mineral reporting: the Conflict Minerals Reporting Template (CMRT), maintained by the Responsible Minerals Initiative (RMI).

The CMRT is a standardized Excel-based questionnaire that flows through the supply chain: 1. A publicly traded company sends the CMRT to its Tier 1 suppliers. 2. Those suppliers complete the template, identifying the smelters and refiners in their own supply chains. 3. The Tier 1 suppliers send the CMRT to their own suppliers (Tier 2), and the process repeats. 4. The data is aggregated, allowing the publicly traded company to identify whether any of the smelters in its supply chain source from conflict-affected regions.

How to complete a CMRT as an SME supplier: 1. Identify every product or component you supply that contains 3TG metals. 2. Map those components back to your own suppliers. 3. Request CMRT declarations from those suppliers. 4. Complete the CMRT at your level, listing the smelters and refiners identified by your suppliers. 5. Declare the scope of your inquiry (company-wide or product-specific). 6. Sign and return the completed CMRT to your customer.

The Incomplete CMRT Trap

The most common compliance failure is returning a CMRT with blank or "unknown" entries for smelter identification. Customers required to file SEC Conflict Minerals Reports cannot accept "unknown." If you repeatedly fail to provide verifiable smelter data, your customer will escalate — potentially to the point of supplier disqualification. The RMI maintains a list of conformant smelters and refiners that have passed independent third-party audits. Smelters on this list are considered low-risk. Your goal should be to trace your supply chain to RMI-conformant smelters wherever possible.

Building Your 3TG Due Diligence Program

Step 1: Product Scoping

Identify every product in your catalog that contains 3TG metals. For electronics manufacturers, this is likely 100% of products. For non-electronics manufacturers, audit your product: does any component use tin solder, tantalum capacitors, tungsten weights, or gold plating?

Step 2: Supplier Engagement

Issue CMRT requests to your direct suppliers of components and materials containing 3TG. Set a clear deadline. Follow up assertively — incomplete supply chain data from your suppliers is the single biggest obstacle to compliance.

Step 3: Smelter Verification

Collect the smelter and refiner names reported by your suppliers. Cross-reference them against the RMI's conformant smelter list and other recognized audit programs (e.g., London Bullion Market Association for gold, Responsible Jewellery Council).

Step 4: Risk Assessment

For any smelter not on a conformant list, assess the sourcing risk. Is the smelter located in or sourcing from the DRC or adjoining countries? Has it been flagged by NGOs or UN reports? Document your risk assessment methodology.

Step 5: File Your CMR (If Applicable)

If you are a publicly traded US company, compile your RCOI results and due diligence findings into the SEC Conflict Minerals Report (Form SD), filed annually by May 31.

How Sustalium Supports 3TG Compliance

Managing CMRT requests across hundreds of suppliers, tracking smelter data, and compiling due diligence reports manually is enormously time-consuming. Sustalium's compliance platform automates and structures this process.

  • Automated CMRT Collection: Send structured CMRT requests to your suppliers through the Sustalium platform. The system tracks response status, sends automated reminders, and flags incomplete submissions.
  • Smelter Verification Engine: Uploaded CMRT data is automatically cross-referenced against the RMI conformant smelter list and other recognized databases. Sustalium instantly identifies high-risk or unverified smelters in your supply chain.
  • Conflict Minerals Due Diligence Wizard: Sustalium guides you through a structured questionnaire covering your supply chain, smelter data, and risk assessment — producing a professional, auditable Conflict Minerals Compliance Declaration that meets both EU and US requirements.
  • Integrated Supply Chain Dashboard: View your entire 3TG supply chain on a single dashboard — from component to supplier to smelter to country of origin — enabling rapid identification of compliance gaps.

Build Your Conflict Minerals Compliance File

Don't let missing CMRT data jeopardize your customer relationships. Demonstrate responsible sourcing and satisfy SEC and EU due diligence expectations.

With Sustalium, you can collect supplier data, verify smelters, and generate a complete Conflict Minerals Compliance Declaration for just €10 per document.

Start Your 3TG Due Diligence Now →

Frequently Asked Questions

Does the US Dodd-Frank rule apply to private companies?

No. The direct SEC filing obligation applies only to publicly traded companies. However, private companies that supply publicly traded customers will receive CMRT data requests and must respond to maintain their supplier relationships.

What is the difference between the RMI conformant list and the CAHRAs list?

The RMI conformant list identifies smelters and refiners that have passed an independent third-party audit of their sourcing practices. CAHRAs (Conflict-Affected and High-Risk Areas) are geographic designations used in the EU Regulation. A smelter can be in a CAHRA and still be RMI-conformant if it sources responsibly.

Is the CMRT the same for the EU and US?

The RMI's CMRT is designed primarily for US Dodd-Frank compliance. For the EU Regulation, the OECD Due Diligence Guidance provides the framework, and the reporting format is specified by the EU. However, the underlying data (smelter identification, country of origin, risk assessment) is substantively the same, and many EU importers use an adapted CMRT.

What if my supplier refuses to complete the CMRT?

Supplier refusal is a significant due diligence red flag. Escalate to your procurement team. If the supplier is critical and non-replaceable, document your reasonable efforts to obtain the data and the supplier's refusal in your own due diligence records. Be prepared to explain to your customers why you cannot provide complete 3TG data.

Last updated: June 22, 2026