The first round of compliance audits under the EU Regulation on Conflict Minerals, introduced at the start of 2021, has begun to reveal both the strengths and shortcomings of corporate due diligence efforts across sectors. Preliminary findings from late 2021 audits suggest that while many companies—particularly large electronics OEMs—have made meaningful strides in formalizing policies and supplier codes of conduct, significant challenges remain in translating these high-level commitments into credible, data-backed supply-chain risk assessments. This is especially true in the mid-tiers of complex global supply networks, where visibility often fades and documentation tends to thin out. As regulators and stakeholders shift their focus from policy intent to operational performance, the role of verifiable data has become central to evaluating whether companies are truly meeting their obligations under the Regulation.
Electronics manufacturers have found particular value in pairing public OECD Due Diligence guidance with open customs and trade datasets to sharpen their supply-chain risk analysis. The OECD framework provides a structured lens through which companies can identify, assess, and mitigate risks of contributing to the financing of armed conflict through their sourcing practices. However, guidance alone is not enough without actionable data. Public customs records, when used intelligently, can illuminate trade routes and supplier linkages that might otherwise escape scrutiny—especially where smelters or refiners source inputs through indirect channels. By overlaying shipment records, declared origins, and harmonized commodity codes with their own procurement data, OEMs can better detect anomalies or red flags that might indicate upstream risk exposure. In this way, open datasets have become an increasingly important tool for companies seeking to move beyond paper-based compliance and toward more resilient, evidence-based due diligence systems.
In preparing annual conflict-minerals risk assessments for submission to national regulators, companies must focus on demonstrating both process and substance. A sound assessment should not only describe policies and training but also show how risk mapping was conducted, what data sources were consulted, and what remedial steps were taken where risks were identified. A practical checklist for companies undertaking this task includes verifying supplier declarations against the OECD’s list of approved smelters and refiners; cross-referencing supplier country-of-origin data with open customs records for consistency; documenting all engagements with suppliers regarding conflict minerals; and recording all risk mitigation measures in a way that can be audited. Importantly, these reports must be more than an exercise in disclosure—they must provide regulators and stakeholders with confidence that risks are being actively identified, managed, and reduced.
The early audit findings underscore a broader dynamic at play: as legal frameworks around supply-chain transparency become more sophisticated, so too must the analytical tools and datasets that companies bring to bear. The EU Regulation on Conflict Minerals was never meant to be satisfied through declarations alone; its underlying logic demands continuous learning, adaptation, and the systematic use of data to bridge the gap between corporate headquarters and far-flung mineral supply chains. For policymakers and economists, this evolving regulatory landscape offers a valuable case study in how compliance mechanisms can help reshape global trade flows, influence sourcing decisions, and ultimately drive more responsible business practices in sectors that have long been vulnerable to governance gaps.