In mid-2019, industry associations representing the electronics and automotive sectors released a comprehensive toolkit designed to help companies comply with the European Union’s Conflict Minerals Regulation (2017). Aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals, the toolkit offered practical templates, checklists, and open data resources to facilitate conflict minerals reporting. This development marked a significant step in preparing supply chains for the EU regulation’s mandatory due diligence requirements, which would come into force on January 1, 2021.
Electronics and automotive purchasers, in particular, were urged to act quickly to integrate the toolkit’s recommendations into their procurement practices. A key feature of the toolkit was its open smelter registry, which provided verified lists of smelters and refiners that had undergone third-party audits. By leveraging this registry, buyers could efficiently screen their supplier networks and identify potential risks linked to tin, tantalum, tungsten, and gold—the so-called 3TG minerals most commonly associated with conflict-affected and high-risk areas. Integrating the smelter registry with existing vendor onboarding modules allowed companies to automate the initial compliance screening process and flag suppliers requiring further due diligence.
Adapting supplier audit templates was another critical priority. The toolkit included model audit questionnaires and site visit checklists, designed to ensure that suppliers not only reported on smelter origins but also demonstrated adherence to chain-of-custody and risk assessment protocols. Companies were encouraged to customize these templates to reflect the specific characteristics of their supply chains, while maintaining alignment with the core OECD framework. For example, automotive firms sourcing complex assemblies were advised to focus audits on component manufacturers most likely to handle 3TG inputs, while electronics brands were encouraged to extend audits deeper into Tier 2 and Tier 3 supplier levels where mineral usage might be more difficult to trace.
Best practices emerging from early adopters emphasized the value of transparency in conflict minerals reporting. Many companies began to develop annual “minerals due diligence” dashboards, which not only satisfied regulatory expectations but also served as a tool for communicating supply chain responsibility efforts to investors, customers, and civil society. These dashboards typically consolidated data from supplier smelter declarations, audit findings, and corrective action plans into a single, user-friendly format. Effective dashboards often featured visual summaries, such as maps showing smelter locations, charts tracking supplier risk profiles over time, and tables highlighting the percentage of 3TG inputs sourced from conflict-free smelters.
Implementing such dashboards required careful data management and cross-functional collaboration. Procurement teams worked alongside compliance, IT, and sustainability departments to ensure data integrity and timely updates. Some firms chose to publish these dashboards on their corporate websites as part of broader sustainability reporting, while others shared them selectively with key stakeholders, such as customers with heightened conflict minerals concerns or regulators seeking evidence of due diligence.
By September 2019, it was evident that the industry toolkit provided an essential foundation for companies seeking to meet the EU Conflict Minerals Regulation’s requirements. However, successful implementation depended on proactive integration of the toolkit’s resources into day-to-day supplier management processes and a commitment to continuous improvement in responsible sourcing practices.