EU importers of tin, tantalum, tungsten and gold (3TG) and of metals containing 3TG should be taking actions now to supplement their compliance programs to address the requirements of the EU conflict minerals regulation. Starting on 1 January 2021, EU importers will be subject to the regulation, which has specific mandatory requirements and consequences.
The EU regulation will impact tens of thousands of European companies – many more than are covered by the US rule. The EU regulation covers many more minerals and metals and has a much wider geographic focus than the US rule. So, what steps should a company take to develop its initial conflict minerals compliance program? Or what steps should a company take to expand its existing compliance program to fulfill the requirements of the EU regulation? You should consider some best practices in building your own compliance program.