The EU’s 2022 Regulation on Responsible Mining marked a major step forward in promoting ethical sourcing and environmental stewardship within global mineral supply chains. Designed to address the risks of human rights abuses, environmental degradation, and corruption often associated with mining activities, the regulation places binding due-diligence obligations on all EU importers of mined products, including critical minerals such as cobalt and nickel. These obligations require companies to map and monitor the full supply chain from mine to smelter, identify and mitigate risks, and transparently report on their findings and actions. As the regulation enters its second year of implementation, metal traders are adapting their compliance frameworks by incorporating recognized international standards and advanced digital technologies to meet these heightened expectations.
A cornerstone of responsible sourcing under the EU regulation is alignment with internationally accepted due-diligence frameworks. Metal traders are increasingly turning to open ITRI (International Tin Research Institute) standards, such as the ITRI Supply Chain Initiative (iTSCi), as part of their traceability and risk management strategies. Although initially developed for tin, tantalum, and tungsten, the core principles of the ITRI framework—chain-of-custody documentation, risk assessments, and third-party verification—have been adapted for cobalt, nickel, and other critical minerals. By adopting ITRI-aligned protocols, metal traders ensure that every step of the supply chain is documented, from mine site to transporters, trading houses, smelters, and refiners. These open standards provide a consistent methodology for tracing mineral flows, verifying origin claims, and addressing identified risks in line with the EU regulation’s requirements.
Beyond standards adoption, the sector is embracing blockchain technology to enhance transparency, integrity, and efficiency in supply chain due diligence. Blockchain solutions enable metal traders to create tamper-proof digital records of transactions, ownership transfers, and compliance checks. Each batch of cobalt or nickel can be assigned a unique digital identity, linked to detailed data about its source, extraction conditions, and movements through the supply chain. This approach significantly reduces the risk of fraud or data manipulation while enabling real-time sharing of verified information among stakeholders, including suppliers, customers, auditors, and regulators. The immutable nature of blockchain records helps companies demonstrate conformance with regulatory requirements while offering a high degree of confidence to downstream customers and investors regarding the ethical provenance of their materials.
To meet the EU regulation’s transparency expectations, metal traders must also ensure that their due-diligence findings and actions are communicated effectively to external audiences. Companies are advised to publish quarterly due-diligence summaries on their corporate websites, providing accessible and meaningful updates on supply chain practices. These summaries should outline the scope of supply chain mapping efforts, the key risks identified during the reporting period, and the specific mitigation measures undertaken. For example, a summary might highlight efforts to reduce sourcing from mines linked to forced labour allegations, steps taken to strengthen supplier contracts with human rights clauses, or actions to support local community development near extraction sites. Publishing these summaries not only fulfills regulatory obligations but also helps build trust with customers, civil society, and investors, demonstrating the company’s commitment to responsible business conduct.
Metal traders developing these summaries should follow a clear process to ensure consistency and accuracy. The first step is to gather and consolidate data from all relevant supply chain partners, including mine operators, transporters, traders, and smelters. This information should cover chain-of-custody records, audit reports, and blockchain-verified data points. The next step is to analyze this data to identify salient risks, such as links to conflict financing, environmental harm, or labour rights violations. Traders should document the methods used for this analysis, including reference to open standards like ITRI or OECD guidelines, and describe the rationale for prioritizing certain risks for mitigation. Finally, the quarterly summary should present these findings in a clear, accessible format, combining narrative explanations with data visualizations where appropriate to enhance transparency and stakeholder understanding.
The adoption of blockchain and open standards for responsible mining due diligence is not without its challenges. Metal traders must ensure that digital systems are interoperable across diverse supply chain actors, including small-scale miners who may have limited technical capacity. Training and capacity-building initiatives, particularly in high-risk regions, are essential to ensure the integrity and completeness of data entered into traceability systems. Additionally, companies should engage with external stakeholders, including NGOs, local communities, and regulators, to validate their due-diligence approaches and ensure alignment with evolving expectations and best practices. By taking these steps, traders can strengthen the credibility of their responsible sourcing programs and contribute meaningfully to the EU regulation’s objectives.
Looking ahead, the EU is expected to continue tightening scrutiny on mineral supply chains as part of its broader sustainable development and green transition agenda. Companies that proactively implement robust due-diligence frameworks, leverage innovative technologies, and prioritize transparency will be better positioned to comply with regulatory developments while safeguarding their social license to operate. The 2022 Regulation on Responsible Mining serves as a catalyst for transforming mineral supply chains, ensuring that the materials essential to modern technologies and the energy transition are sourced in a manner that respects human rights, protects the environment, and supports ethical trade.