Conflict Minerals

The term conflict minerals typically refers to four metals — tin, tungsten, tantalum, and gold, collectively known as 3TG — when mined in conditions of armed conflict or human rights abuse and sold to fund combatants. The concept emerged from advocacy around the wars in the Democratic Republic of the Congo (DRC) and its neighbors, where militias and elements of national armies have controlled artisanal mines in provinces such as North Kivu, South Kivu, and Ituri.

These minerals matter globally because they feed core industrial supply chains: tantalum into capacitors for phones and laptops, tin into solder, tungsten into cutting tools and electronics, and gold into jewelry and finance. That linkage between consumer goods and frontline violence drove a wave of regulation in the 2010s.

Key instruments include:

• Section 1502 of the U.S. Dodd-Frank Act (2010), which requires SEC-listed companies to disclose use of 3TG sourced from the DRC and adjoining countries and to conduct supply-chain due diligence.
• The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, first published in 2011, which became the de facto international standard.
• EU Regulation 2017/821, in force for importers from 1 January 2021, imposing due diligence obligations on EU-based importers of 3TG above set volume thresholds.

Industry initiatives such as the Responsible Minerals Initiative (formerly CFSI) operate smelter audit programs to certify "conflict-free" refiners. Critics argue that Dodd-Frank's de facto embargo effect temporarily harmed legitimate Congolese miners, while others note continued smuggling through neighboring states and the spread of the problem to cobalt and other battery metals not formally covered by 3TG rules. Debate continues over whether due diligence regimes meaningfully reduce armed-group revenue or merely shift sourcing patterns.