EU Conflict Minerals - Mandatory Obligations for Downstream Companies


Our company doesn't import the 3TGs directly into Europe, but we do import electronics that contain 3TGs. I'm uncertain how the EU regulation for importers will impact us.
Since we only import completed electronics (like power supplies or speakers), it would seem this regulation would not apply. Is this understanding correct?


The mandatory obligations do not apply to products which are not covered under Annex I of the regulation (see link below).

Downstream companies like yours will be expected to voluntarily adopt tools and programs to demonstrate supply chain due diligence of conflict minerals. If the EU Commission determines that insufficient adoption is occurring within downstream companies, they will introduce mandatory legislation.


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