The European Union’s Conflict Minerals Regulation, which came into force in January 2021, was already considered by many to be a landmark in the global effort to reduce the trade in minerals that fund violence and human rights abuses. But as with so many regulatory frameworks, the first year of implementation revealed gaps—practical ambiguities that stakeholders, from importers to refiners to manufacturers, struggled to navigate. Responding to this, the EU introduced its first amendment to the regulation in August 2021. The adjustment, though seemingly modest, had wide-reaching implications: it clarified what constitutes a “derivative” mineral. The consequences of this clarification rippled through supply chains, particularly for industries where gold is transformed and reprocessed in myriad ways, such as jewelry manufacturing.
Prior to the amendment, the definition of derivatives had, at times, been a source of confusion or even quiet contention. The regulation’s original language left room for interpretation—what degree of processing removed a mineral from its regulated status? Could recycled content be treated differently? With the amendment, the EU sought to shut down loopholes that some operators might have inadvertently or deliberately relied on. In effect, the amendment made clear that the regulation’s due diligence requirements apply not only to raw ores and concentrates but also to certain refined products and semi-fabricated forms, regardless of how many transformations they might have undergone after extraction.
This greater precision has forced a reckoning within the jewelry sector. Manufacturers and retailers alike have found themselves reassessing how they trace gold through complex, often fragmented supply chains. The pressure is no longer limited to those sourcing directly from mining operations. Even firms relying on intermediates, alloys, or recycled material must now grapple with the expectation of traceability. The task isn’t trivial. Gold, by its nature, is highly fungible. Once refined and melted, the metal loses all physical markers of origin. Supply chain transparency thus hinges almost entirely on documentation, audit trails, and the credibility of upstream partners.
One tool proving indispensable in this landscape is the open refinery data published by the London Bullion Market Association (LBMA). The LBMA’s Good Delivery List has long served as a benchmark for refinery integrity, but manufacturers are increasingly turning to the association’s openly available audit and certification data. This data offers visibility into which refineries have undergone third-party conflict-mineral audits and met responsible sourcing standards. For jewelry firms seeking to demonstrate compliance with the EU’s tightened rules, linking their gold inputs to LBMA-certified refineries provides a measure of assurance—though not, of course, a guarantee.
But how should a jewelry manufacturer practically integrate LBMA data into its supply chain due diligence? One starting point is to map gold suppliers and intermediaries against the LBMA’s published list of certified refiners. This exercise, admittedly, can feel painstaking. Supplier declarations often reference refinery names or locations, but the granularity of information varies. Some manufacturers have found value in requesting additional documentation, such as refinery certificates or LBMA audit summaries, directly from their suppliers. The aim is to establish a paper trail connecting purchased gold to an LBMA-certified source—or, at the very least, to identify where such a trail breaks down.
In parallel, firms should consider enhancing their internal reporting frameworks to reflect these linkages. The amended regulation places a premium on transparency, not only within the supply chain but also outwardly, through published due diligence reports. A robust mineral due diligence report might, for instance, set out the company’s sourcing policy, describe the procedures used to assess supplier compliance, and detail any identified risks or mitigation measures taken. It’s important here not to fall into the trap of over-engineering these reports to the point where they become unreadable or opaque. The objective should be clarity—communicating the company’s approach and challenges in a manner that regulators, investors, and civil society can reasonably follow.
For manufacturers seeking a structured approach, the OECD’s Due Diligence Guidance remains the de facto standard. Jewelry firms could frame their reporting around the OECD’s five-step framework: establishing strong company management systems, identifying and assessing risks, designing and implementing responses, carrying out independent audits, and reporting publicly. Overlaying this structure with the specific requirements of the EU regulation—and now, its amendment—can help ensure that reports meet both regulatory and stakeholder expectations.
The reality, though, is that publishing due diligence reports isn’t just about ticking a compliance box. It’s about demonstrating credibility in a marketplace where consumers, too, are becoming savvier about supply chain ethics. Jewelry brands, in particular, operate in a sector where public perception is finely tuned to notions of purity, ethics, and value. A gold chain or ring may carry with it unspoken assumptions about how the metal was sourced. And while the EU regulation compels certain disclosures, the reputational stakes for going beyond the minimum are high enough that many companies are choosing to do so voluntarily.
All of this creates a somewhat paradoxical situation. The amendment, by clarifying the definitions around derivatives, was intended to remove ambiguity. Yet in practice, it has forced companies to confront the underlying complexity of their gold supply chains in ways that feel anything but clear-cut. There are grey areas still—particularly when it comes to recycled gold or mixed-source products, where chain-of-custody documentation can thin out. And, as firms adjust to this new reality, some are undoubtedly questioning whether the cost and administrative burden of compliance will ultimately reshape sourcing patterns across the industry.