The release of the first annual implementation report for the EU Conflict Minerals Regulation in January 2021 provided a timely window into how sectors such as automotive and electronics are responding to the increasingly complex task of auditing their tin, tungsten, tantalum, and gold (commonly referred to as 3TG) supply chains. The Regulation, which came into force on January 1, 2021, has compelled companies across Europe to take a hard look at the provenance of these critical minerals. It has also raised challenging questions about the adequacy of current due-diligence frameworks, the reliability of supplier declarations, and the practicalities of verifying compliance in multi-tiered, often opaque global supply networks.
What became clear from the report is that progress has been uneven. Some firms, particularly those in the automotive sector with longstanding exposure to conflict minerals issues, appear to have moved relatively swiftly to integrate new audit requirements into existing compliance systems. Others, especially smaller electronics manufacturers or those with more fragmented supply bases, have struggled to adapt. This is perhaps unsurprising. The complexities of tracing minerals from smelters and refiners back to their source are considerable, and even well-resourced companies face significant hurdles in achieving full visibility. Supplier declarations, while a necessary foundation, are not sufficient on their own. Without meaningful verification, they risk becoming little more than paperwork exercises.
It is here that the OECD’s updated open data repository of smelters has proven invaluable. The repository, which lists smelters and refiners that have undergone independent third-party audits, offers procurement teams a practical starting point for cross-verifying supplier claims. But the utility of the database hinges on how well companies can integrate this information into their internal audit and compliance workflows. This is where some organizations have begun to distinguish themselves. Leading firms have developed automated processes to match supplier-declared smelter IDs against the OECD’s lists, flag discrepancies, and trigger follow-up inquiries. Others are still grappling with manual lookups or fragmented data sources, which slows down response times and increases the risk of errors.
For firms still building their capacity in this area, it may be useful to consider a structured approach. The first step is to establish a comprehensive internal register of all suppliers that provide 3TG-containing components or materials. This register should capture not only direct Tier 1 suppliers but, as far as possible, the upstream smelters and refiners they source from. Where suppliers provide incomplete or inconsistent information—which, frankly, will often be the case—companies should document these gaps and set clear timelines for remediation. It may be tempting to assume that declarations from trusted suppliers can be accepted at face value. However, the implementation report highlighted several instances where well-regarded suppliers inadvertently passed on incorrect or outdated information. A cautious, evidence-based mindset is therefore essential.
Once the internal register is established, firms should create a repeatable process for cross-verifying each smelter ID with the OECD repository. This can be done manually in the early stages, but as data volumes grow, some form of automation becomes highly desirable. Even simple scripts or database queries can significantly reduce the burden. The key is to ensure that any discrepancies—whether a declared smelter does not appear on the OECD list, or appears with a different status than claimed—are promptly flagged and investigated. Firms should resist the urge to dismiss small anomalies as irrelevant. In the world of conflict minerals compliance, small anomalies have a habit of pointing to larger issues downstream.
To support consistent reporting and transparency, companies may wish to adopt a model due-diligence report format that highlights key performance indicators. Such a format could include metrics such as the percentage of supplier declarations received, the proportion of declared smelters verified against the OECD database, the number of discrepancies identified, and the resolution rate of these discrepancies. It might also track the proportion of supply that can be traced back to smelters and refiners that have passed third-party audits. This kind of structured reporting not only supports internal governance but also positions firms to meet stakeholder expectations for transparency.
A well-designed due-diligence report does not need to be complex. What matters is clarity and consistency. Firms might consider including narrative sections that explain the methodology used, the challenges encountered, and the steps being taken to address outstanding issues. It is often in these narrative sections that the reality of supply chain complexity comes through most clearly. No company will have perfect visibility. What stakeholders—and increasingly, regulators—expect is evidence of a serious, sustained effort to improve that visibility over time.
There is, of course, a broader context to all of this. The implementation report’s findings reflect not just technical compliance challenges but also deeper tensions in how global supply chains are structured. The fact that companies struggle to trace 3TG minerals to their source speaks volumes about the fragmentation and opacity of many modern supply networks. As regulatory and investor pressure mounts, firms will need to think not only about how to comply with existing rules, but about how to build supply chains that are genuinely more transparent and resilient. That is a task that will require sustained effort, collaboration, and—perhaps most importantly—a willingness to confront uncomfortable truths about where materials come from and how they are produced.