When the EU Conflict Minerals Regulation came into force in 2017, the electronics sector was among the industries most directly affected. It’s perhaps no surprise. The very components that power our modern devices—tiny yet critical—are often the ones most entangled in complex, opaque supply chains. From 2017 through 2022, regulators, companies, and civil society groups have grappled with what it means to trace the origins of minerals like tin and tantalum in a meaningful, enforceable way. The lessons emerging from this period are… mixed. There’s been real progress in some quarters, and yet, lingering gaps remain—particularly where smaller electronics OEMs are concerned. They often lack the resources or leverage of their larger counterparts, which complicates compliance and increases risk exposure.
One of the key enforcement trends over this period has been the gradual tightening of expectations regarding documentation. Early on, some firms seemed to think that broad supplier assurances would suffice. Regulators, over time, signaled that wasn’t enough. The EU’s focus shifted more decisively towards verifiable data, not just self-declarations. This evolution caught certain electronics disruptors off-guard. While large, established OEMs typically had teams dedicated to compliance, many smaller firms—particularly those in the startup or scale-up phase—struggled to keep pace. Their business models, after all, are often built around agility and rapid innovation, not painstaking supply chain audits.
The EU’s enforcement approach also reflected a somewhat cautious pragmatism. Rather than launching aggressive, high-profile prosecutions, authorities concentrated on capacity building and corrective action. This has meant that the regulatory environment, while firming, hasn’t felt overly punitive. Yet this relative leniency is unlikely to last indefinitely. As public scrutiny intensifies and as more tools for supply chain mapping become available, tolerance for vague or incomplete conflict minerals reporting is eroding. Small OEMs would do well to anticipate this shift rather than wait for formal warnings or penalties.
Fortunately, resources to assist these firms have become more accessible. One of the more promising developments is the expansion of the EU ORES datasets—the Open Repository for Environmental Sustainability. These datasets aggregate trade flows, smelter locations, and processing records that can be instrumental in tracing tin, tantalum, and other conflict minerals back through the supply chain. While ORES is by no means comprehensive, and the data can at times feel patchy or inconsistently updated, it provides a valuable starting point. Small electronics manufacturers, who may lack the budget for costly proprietary data services, can leverage ORES to build baseline maps of their mineral flows.
Of course, doing so effectively requires some internal organization. Firms need to assign responsibility—whether that means a compliance officer, a procurement manager, or even a cross-functional team—to engage with the data, interpret it, and, crucially, act on it. Too often, data mapping efforts stall because no one owns the process end-to-end. And this is where things can get a bit messy. Some firms attempt to map flows once, tick the compliance box, and move on. But supply chains shift. Smelters change sourcing patterns. Without periodic updates, these mapping exercises risk becoming obsolete almost as soon as they are completed.
For those firms looking to formalize their efforts, developing a conflict-minerals risk classification framework is an increasingly standard step. A simple template could, for instance, categorize suppliers and material sources into tiers: low-risk (fully verified smelters with audited conflict-free certifications), medium-risk (smelters with partial documentation or newer entrants undergoing audit), and high-risk (unknown smelters or those flagged in public reports for non-compliance or sourcing concerns). The point isn’t to create a perfect system—there’s no such thing. Rather, it’s to establish a structured way of identifying where risks cluster so that mitigation efforts can be prioritized. This can also help when preparing regulatory filings or responding to investor queries, which, as many in the sector can attest, are becoming more detailed and probing.
One point that often causes confusion among smaller OEMs is how far down the supply chain their due diligence is expected to go. The regulation is clear enough in its intent, but real-world application tends to be more nuanced. Ideally, firms would trace materials right back to the mine. In practice, reaching beyond the smelter level is, for many, still aspirational. This isn’t to say that deeper traceability should be ignored, only that efforts need to balance ambition with realism. Incremental improvements—say, verifying an additional layer of processing beyond what was covered last year—are still progress.
The question of whether enforcement will become more assertive in the years ahead is hard to answer definitively. Signals point in that direction, but regulators have to weigh the potential economic impact of pushing too hard, too fast. After all, the electronics sector, particularly in Europe, is an engine of innovation. Policymakers are aware of the risks of overburdening smaller players. Yet, at the same time, public expectations around ethical sourcing show no signs of retreating. The tension is, perhaps inevitably, baked into the system.