The EU Conflict Minerals Regulation and the Labyrinth of Brexit

    View Author March 2021

    The initial provisions of Regulation (EU) 2017/821 of the European Parliament and of the Council laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas (the “EU Conflict Minerals Regulation”) took effect in 2017. Then, on January 1, 2021, the rest of the provisions of the EU Conflict Minerals Regulation (as amended) came into full effect requiring supply chain due diligence and, in certain cases, third-party audits and consultations. The supply chain due diligence required by the Regulation is based on the due diligence framework set out in the OECD’s Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

    This publication addresses the impact of Brexit on the effectiveness of the EU Conflict Minerals Regulation on importers into England, Scotland, Wales, and Northern Ireland.