What is Conflict Minerals?

What is Conflict Minerals?

Conflict minerals refers to natural resources—primarily tin, tantalum, tungsten, and gold (collectively known as 3TG)—that are mined in conditions of armed conflict and human rights abuse, particularly in the Democratic Republic of the Congo (DRC) and adjoining countries in the Great Lakes region of Central Africa. Revenue from these minerals has financed armed groups responsible for widespread atrocities, forced labor, and environmental destruction. The term has expanded in scope to encompass cobalt, mica, and other minerals associated with exploitation and conflict globally.

Why It Matters

The human cost of conflict mineral extraction is staggering. The DRC's eastern provinces have experienced over two decades of armed conflict fueled in part by mineral wealth, with an estimated 6 million deaths and millions of displaced people. Artisanal and small-scale mining operations, which produce a significant share of global tantalum and cobalt supply, frequently involve child labor, forced labor, and hazardous working conditions. The International Labour Organization estimates that over one million children work in mining globally.

Regulatory frameworks have established binding obligations. The U.S. Dodd-Frank Act (Section 1502, enacted 2010) requires SEC-reporting companies to disclose whether their products contain conflict minerals originating from the DRC or adjoining countries and to describe their due diligence efforts. The EU Conflict Minerals Regulation (2021) mandates supply chain due diligence for EU importers of 3TG minerals and metals above specified volume thresholds, aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

For electronics, automotive, aerospace, and medical device manufacturers, conflict mineral compliance is a material supply chain concern. These industries are the primary downstream consumers of 3TG minerals, and customer expectations—particularly from major OEMs—cascade compliance requirements through multiple supply chain tiers. Companies unable to demonstrate responsible sourcing face contract exclusion, regulatory penalties, and reputational damage.

The scope of concern is broadening. Cobalt, essential for lithium-ion batteries powering electric vehicles and consumer electronics, has become a focal point due to well-documented child labor and artisanal mining abuses in the DRC, which produces roughly 70% of global cobalt supply. Mica, used in cosmetics and electronics, faces similar scrutiny following investigations of child labor in Indian and Malagasy mines.

How It Works / Key Components

Conflict mineral due diligence follows the OECD's five-step framework: establish strong management systems, identify and assess supply chain risks, design and implement a strategy to respond to identified risks, carry out independent third-party audits of smelters/refiners, and report on due diligence. The Responsible Minerals Initiative (RMI), an industry coalition, administers the Responsible Minerals Assurance Process (RMAP), which audits smelters and refiners against these standards.

Supply chain mapping is the foundational challenge. A single electronic device may contain minerals processed through dozens of smelters and refiners, sourced from mines across multiple continents. The Conflict Minerals Reporting Template (CMRT), developed by the RMI, standardizes data collection from suppliers, enabling companies to trace mineral origins through complex multi-tier supply chains. The Extended Minerals Reporting Template (EMRT) covers cobalt and mica.

Responsible sourcing programs aim to maintain market access for legitimate artisanal miners while eliminating conflict-linked supply. Programs like the ITSCI (ITRI Tin Supply Chain Initiative) tag and trace minerals from mine site to smelter in the DRC and neighboring countries. Fair trade and certified mining initiatives provide alternative supply channels, though scale remains limited relative to global demand.

Companies face a strategic choice between avoidance (sourcing only from conflict-free regions) and engagement (continuing to source from conflict-affected areas through verified responsible channels). Blanket avoidance, while simpler operationally, can devastate legitimate mining communities and push informal mining further underground. The OECD guidance explicitly discourages de facto embargoes in favor of risk-based engagement.

Council Fire's Approach

Council Fire advises organizations on conflict mineral due diligence programs that balance regulatory compliance with responsible engagement in affected regions. Our approach integrates mineral supply chain transparency with broader human rights and environmental due diligence frameworks, reflecting our commitment to supply chain practices that serve both business integrity and community resilience.

Frequently Asked Questions

What are the 3TG minerals and where are they used?

Tin (used in solder, tin plating, and alloys), tantalum (capacitors and high-performance electronics), tungsten (cutting tools, electronics, and industrial applications), and gold (electronics, jewelry, and financial instruments). These minerals are present in virtually all electronic devices, automotive components, aerospace parts, and medical equipment. Their ubiquity means that nearly every manufacturer with electronic components in their products has potential exposure.

How effective has conflict mineral regulation been?

Results are mixed. The Dodd-Frank Act and EU Regulation have increased transparency and driven significant industry investment in traceability systems. The percentage of smelters and refiners participating in RMAP audits has grown substantially. However, armed groups have adapted, and conflict-linked minerals continue to enter global supply chains through smuggling and laundering. Independent assessments suggest that regulation has reduced but not eliminated conflict financing from minerals, and that complementary governance, development, and security interventions are essential.

What is the Responsible Minerals Initiative?

The RMI is the leading industry coalition for responsible mineral sourcing, with over 400 member companies across electronics, automotive, and other sectors. It administers the RMAP audit program for smelters and refiners, develops and maintains reporting templates (CMRT and EMRT), and provides tools, training, and due diligence guidance. RMI's audit findings are shared with downstream companies, enabling industry-wide risk assessment without duplicative auditing.