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.
Table of Contents
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:
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.
Cut manual effort, stay audit-ready, and gain full supply-chain visibility with one integrated solution for conflict minerals compliance.
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.
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.
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.
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.
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:
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.
Managing conflict minerals data across complex, multi-tier supply chains is a demanding task – especially when accuracy, scalability, and audit-readiness are non-negotiable. IPOINT’s Conflict Minerals Software is designed to meet exactly these challenges by automating and standardizing the entire reporting process.
The solution supports the use of industry-standard templates, including the Conflict Minerals Reporting Template (CMRT) developed by the Responsible Minerals Initiative (RMI). This ensures structured supplier communication, consistent data validation, and full traceability across the reporting chain.
Whether you're navigating your first reporting cycle or scaling a global compliance program, iPoint provides the digital foundation for reliable, future-proof conflict minerals management.
Conflict minerals compliance may start with regulation – but forward-looking companies use it to build something bigger: trust, transparency, and long-term supply chain resilience. The tools are there. The frameworks are clear. The real difference lies in how consistently and proactively they are applied – as part of a broader commitment to .responsible and sustainable sourcing.