Conflict minerals, also known as 3TG: Tungsten, Tin, Tantalum, and Gold, later adding Cobalt, refer to minerals mined under conditions of armed conflict and human rights abuses, particularly those mined in the eastern provinces of the Democratic Republic of Congo (DRC), controlled by the Congolese government army and numerous armed rebel groups such as the Democratic Forces for the Liberation of Rwanda (FDLR) and the National Congress for the People's Defence (CNDP). The plundering of Congo's natural resources is not limited to Congolese nationals; during the war, countries such as Uganda, Rwanda, and Burundi also profited from Congo's resources. Today, government agencies in these countries continue to smuggle Congolese resources, using the profits to support the Second Congo War, and control of areas rich in minerals has become a key focus of the war. Common minerals include cassiterite, wolframite, coltan, and gold, originating from eastern Congo and passing through multiple suppliers before reaching various electronics companies. These mineral raw materials are indispensable components of everyday devices, such as mobile phones and laptops.

　　After being mined in eastern Congo, the minerals are transported out of Congo through multiple hands, passing through neighboring Uganda or Burundi before reaching processing plants in East Asia. In view of this, the US Conflict Minerals Act applies to minerals from the Democratic Republic of Congo and nine surrounding countries, including Angola, Burundi, the Central African Republic, the Republic of Congo, Uganda, Sudan, Tanzania, Rwanda, and Zambia.

　　Background

　　Because armed forces in Congo and surrounding countries frequently use the mining of 3TG (Tungsten, Tin, Tantalum, and Gold) as a source of funding, fueling significant regional bloodshed. Due to the human rights abuses and environmental damage caused by conflict minerals, the US Securities and Exchange Commission (SEC) passed the Dodd-Frank Conflict Minerals Act (DFCM) on August 22, 2012, requiring publicly traded US companies to investigate and disclose information about their suppliers if their products use these minerals. Companies must also complete Form SD annually, starting in 2013, reporting on the use of conflict minerals in product manufacturing to cut off funding for armed groups.

　　Due to the transnational and regional nature of conflict minerals, the European Union published Regulation (EU) 2017/821 in the Official Journal on May 19, 2017, as the EU version of the Conflict Minerals regulation. According to this regulation, from January 1, 2021, importers, smelters, and refiners of 3TG within the EU must conduct mandatory due diligence to confirm that 3TG originates from non-conflict areas when annual imports exceed a certain threshold.

　　Applicable Regions

　　United States, European Union

　　About Conflict Minerals

　　Five Conflict Minerals

　　Coltan (Ta) is an ore from which tantalum is extracted. Tantalum is a key raw material for tantalum capacitors, used in high-performance, small-size, and high-reliability devices, ranging from hearing aids and pacemakers to automotive airbags, GPS, ignition systems, and anti-lock braking systems, to laptops, mobile phones, game consoles, and digital cameras. In its carbide form, tantalum possesses high hardness and wear resistance, making it suitable for use in engine and turbine blades, drill bits, grinding tools, and other tools.

　　Cassiterite (Sn) is the main raw material for smelting tin. Tin is used to make cans and solder for electronics, and can also be used to make antimicrobial and antifungal agents, or as tributyltin, a raw material for polyvinyl chloride and high-grade coatings.

　　Wolframite (W) is the main source of tungsten. Tungsten is a high-density metal, a property that makes it useful in fishing weights, dart heads, and golf club heads.

　　Gold (Au) is used in jewelry, electronics, and dental products.

　　Cobalt (Co) is mainly used in the manufacture of magnetic, wear-resistant, and high-strength alloys; cobalt-chromium alloys are used in dental fillings; lithium cobalt(III) oxide is widely used in lithium-ion batteries (lithium cobalt oxide batteries); cobalt also has wide applications in electroplating, and due to its attractive appearance, hardness, and oxidation resistance, it is also used as an underglaze for porcelain enamel.

　　Industry Practices

　　The Conflict Minerals Act affects not only publicly traded companies targeted by the US SEC, but every manufacturer selling metal products to these US companies, and other manufacturers selling to these first-tier supply chain companies. If your customer is under the SEC's purview, they are affected by the act, as these US companies place great importance on Corporate Social Responsibility (CSR), a key factor influencing investment and trading indicators. However, companies that actually use conflict minerals will not be penalized, but may experience a significant drop in stock price. Considering this, more and more US companies are setting a precondition of "not using conflict minerals." The industry potentially using conflict minerals is electronics manufacturers.

　　According to the act, any product containing metal components is subject to regulation and investigation. These affected manufacturers must prove or trace back whether their products contain conflict minerals, fulfilling their responsibility to disclose the origin of materials and declare that their products are conflict-free (DFCM-Free). Whether metal or non-metal materials, they may contain metal components, and manufacturers must conduct "due diligence".

　　Responsible Organizations: The Responsible Business Alliance (RBA, formerly the Electronic Industry Citizenship Coalition, EICC) and the Responsible Minerals Initiative (RMI, formerly the Global e-Sustainability Initiative, GeSI) have developed the "Conflict-Free Smelter Program" and the "Conflict Minerals Reporting Template" (CMRT), requiring their members and suppliers to investigate and disclose the mineral sources in their supply chains for commonly used metals such as gold (Au), tantalum (Ta), tungsten (W), tin (Sn), and cobalt (Co) in electronic products, to avoid sourcing from conflict regions.

　　Investigation Period: US listed companies must submit their Form SD report by May 31 of the following year, reporting on the use of conflict minerals in products manufactured between January 1 and December 31 of the previous year.

　　Report Content: Output due diligence results (investigation methods for country of origin, mine, and acquisition channels), confirming whether the metals contained in the product are from the RBA-certified smelter list, currently containing approximately five to six hundred smelters. If the product contains conflict minerals originating from the Democratic Republic of Congo and its neighboring countries, a "Conflict Minerals Report" (CMRT) must be created, submitted after inspection by a third-party organization, and published on the company website. The report should describe the products using conflict minerals, processing facilities, etc. If the conflict minerals are recycled materials, no investigation is necessary. The content of the investigation form must be updated twice a year.