Conflict Minerals Explained: Understanding 3TG and Their Compliance Impact

Conflict minerals – tin, tungsten, tantalum, and gold (3TG) – are essential raw materials in countless modern products, from smartphones to cars and medical devices. But their extraction often takes place in conflict-affected and high-risk areas, where mining can finance armed groups and contribute to severe human rights abuses.

Growing regulatory demands and rising expectations around environmental, social, and governance (ESG) performance are putting conflict minerals compliance back in the spotlight. For manufacturers, compliance is no longer just a legal obligation – it’s a cornerstone of ethical sourcing and transparent supply chains.

This article explains what conflict minerals are, why they matter, and how compliance requirements are shaping the way companies source and report 3TG. 

What Are Conflict Minerals and How Are They Used in Manufacturing?

Conflict minerals refer to four key raw materials – tin, tungsten, tantalum, and gold – collectively known as 3TG. Under U.S. regulations, the term applies to 3TG that are necessary to the functionality or production of a product. Globally, responsible sourcing initiatives and the EU Conflict Minerals Regulation use a broader approach, covering 3TG from any conflict-affected and high-risk area (CAHRA), not just the Democratic Republic of Congo and its adjoining countries.

These minerals are considered critical in manufacturing due to their unique physical and chemical properties. However, in CAHRAs, mineral extraction has historically financed armed groups and contributed to severe human rights violations.

What are conflict minerals used for in practice? 
Their applications span almost every modern industry:

• Electronics: Tin is essential for soldering components on circuit boards; tantalum is used in capacitors for smartphones and laptops; gold ensures conductivity and corrosion resistance in high-precision devices.
• Automotive: Tungsten is used to harden tools and components in engines and safety systems; gold and tin are present in connectors and electronic control units.
• Medical devices: From implantable electronics to diagnostic equipment, 3TG ensures high reliability and durability under strict performance standards.
• Industrial machinery and aerospace: Tungsten’s strength and heat resistance make it indispensable for turbines, cutting tools, and high-stress applications.

Given their widespread use, 3TG are embedded deep within global supply chains. For internationally operating companies, identifying the presence of these materials is an essential step toward conflict minerals compliance and alignment with responsible sourcing principles. Without proper traceability, businesses risk unintentional links to unethical practices, non-compliance with regulations, and reputational damage.

Image: Luwowo coltan mine near Rubaya, North Kivu – certified under the CIRGL-RDC system as conflict-free. Coltan, short for columbite–tantalite, is the main source of tantalum used in electronic capacitors.

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Compliance Challenges: Key Regulations and Business Implications

Conflict minerals compliance is shaped by a complex and evolving regulatory landscape. Companies that manufacture or contract to manufacture products containing 3TG that are necessary to the functionality or production of those products must navigate several legal frameworks, each with specific reporting obligations, due diligence expectations, and supply chain risk management requirements.

Dodd-Frank Act Section 1502

In the United States, conflict minerals compliance is primarily driven by Dodd-Frank Act Section 1502. Companies registered with the U.S. Securities and Exchange Commission (SEC) – including foreign issuers – must determine whether any 3TG used in their products originated in the Democratic Republic of Congo or adjoining countries (collectively known as “Covered Countries”).

If so, they must conduct a reasonable country-of-origin inquiry and, where applicable, submit detailed Conflict Minerals Reports with the SEC. These reports describe the company’s due diligence process – following the five-step framework of the OECD Due Diligence Guidance – and outline measures taken to ensure responsible sourcing.

While the core disclosure requirements remain in force, enforcement of the “DRC conflict free” determination has been relaxed since 2017, yet companies are still obligated to file accurate and timely reports.

EU Conflict Minerals Regulation

Since 2021, the EU Conflict Minerals Regulation imposes direct obligations on EU importers of 3TG in raw or semi-processed form above defined thresholds. Unlike the U.S. rule, it applies globally to all conflict-affected and high-risk areas (CAHRAs) and mandates third-party audits for smelters and refiners. Importers must assess supply chain risk, implement corrective actions where necessary, and maintain transparent records to demonstrate compliance to their national competent authority on an annual basis.

Beyond Legal Obligations

In addition to these binding regulations, many companies face increasing pressure from customers, investors, and internal ESG initiatives to implement voluntary conflict minerals programs. Stakeholders expect companies to demonstrate not only legal compliance, but also a proactive stance on responsible sourcing and supply chain transparency.

This requires structured due diligence processes aligned with the OECD Guidance, clear internal roles, and scalable tools for supplier engagement and risk monitoring. Without these foundations, organizations may struggle to keep pace with regulatory change and rising market expectations.

How to Manage 3TG Reporting Efficiently

For many companies, the first step toward conflict minerals compliance is understanding what needs to be reported – and how. The most widely used tool for this purpose is the Conflict Minerals Reporting Template (CMRT), developed by the Responsible Minerals Initiative (RMI), which is updated annually to reflect changes such as new smelter IDs, revised audit program statuses, and format improvements.
It provides a standardized framework for collecting, organizing, and sharing data about 3TG sourcing within global supply chains and is designed to align with the OECD Due Diligence Guidance’s five-step framework.

Using the CMRT, companies must request information from their suppliers, including whether the materials used contain 3TG, which smelters or refiners are involved, and whether these facilities are certified by recognized audit programs. Best practice includes cross-checking smelter and refiner IDs against the RMI Conformant Smelter List or equivalent databases to verify audit status and identify high-risk sources.

 But collecting supplier responses is only part of the process. Businesses must also validate the information for completeness, consistency, and plausibility – especially when preparing audit-ready documentation for regulators, customers, or internal audits.

Key challenges in this process include:

• Ensuring high supplier response rates
• Identifying and resolving data gaps or inconsistencies
• Tracing materials across multi-tier supply chains
• Staying aligned with evolving reporting standards (including other RMI templates such as the Extended Minerals Reporting Template – EMRT – for materials like cobalt, mica, or lithium)

For companies newly affected by regulations or expanding their scope of compliance, it’s critical to establish internal processes that can scale – not just for today’s reporting needs, but for future requirements as well. Structured reporting through tools like the CMRT ensures comparability, transparency, and readiness for formal disclosures, including reports with the SEC or requests from EU authorities.