India’s Ministry of Mines issued its Responsible Minerals Sourcing Guidelines in August 2021, marking a significant step in the country’s effort to align its mineral procurement practices with global expectations on conflict minerals. The guidelines target the responsible sourcing of tin, tantalum, tungsten, and gold (3TG minerals), and they are already beginning to influence the operational decisions of domestic electronics manufacturers. Early industry responses have shown a clear focus on establishing traceability systems that can stand up to international scrutiny while remaining practical for India’s highly fragmented mineral supply chains.

 

At the core of the guidelines is a call for manufacturers to map their supply chains in detail, identifying potential risks linked to 3TG sourcing. The government’s launch of the Minerals Open Source System (MOSS) portal offers a critical tool in this effort. MOSS provides an open dataset that lists registered mining operations, including their location, production volumes, and basic compliance status with environmental and labor regulations. For electronics manufacturers, the immediate task is to link procurement data with this portal to gain visibility into the origins of the minerals entering their production lines. This requires careful mapping of supplier declarations against MOSS records, verifying that smelters and refiners are sourcing only from listed, low-risk mines.

 

Integrating the MOSS dataset with internal procurement systems can be achieved through a structured, phased approach. First, firms should download the MOSS data extract relevant to the minerals they source. This dataset can then be converted into a format compatible with the company’s ERP or supplier-management systems. The next step is to establish automated cross-checks between incoming supplier documentation and the mine registry data, flagging any instances where declared sources do not match registered low-risk sites. Some manufacturers have begun setting up dashboards within their procurement software that provide real-time visibility of mineral source compliance, enabling quicker intervention when anomalies arise. For companies without advanced systems, even manual reconciliation of supplier declarations with the MOSS data on a quarterly basis can offer a valuable starting point.

 

The guidelines also emphasize the importance of transparency through public reporting. Electronics manufacturers are encouraged to publish annual compliance summaries that list the sources of 3TG minerals used, highlight any high-risk sites identified during the year, and detail the remediation steps taken. A well-structured compliance summary should outline the due diligence process applied, describe how MOSS and other tools were used in risk assessments, and provide a clear account of supplier engagement measures—such as capacity building or contract termination—in response to identified issues. The goal of these reports is not just to meet regulatory requirements but also to build trust with customers, investors, and civil society stakeholders increasingly attuned to supply chain ethics.

 

As the first year of implementation unfolds, Indian electronics manufacturers face both opportunity and challenge. The Responsible Minerals Sourcing Guidelines provide a framework that can enhance international competitiveness by demonstrating alignment with global sourcing norms. But they also demand rigorous, sustained effort in integrating open data, strengthening supplier engagement, and delivering credible transparency. The industry’s ability to rise to this challenge will shape India’s reputation in responsible mineral sourcing for years to come.