Why Conflict and High-Risk Minerals Matter
Conflict minerals like tin, tantalum, tungsten, and gold (3TG) and high-risk minerals – such as cobalt, mica, lithium, and nickel – are essential to a wide range of industries, from electronics and aerospace to automotive and cosmetics.
However, the extraction of these minerals is often linked to the financing of armed conflicts, human rights abuses, hazardous working conditions, and child labor. To address these risks, regulators in various jurisdictions have introduced binding due diligence requirements – mandating companies to demonstrate that their supply chains are transparent and responsibly managed.
The OECD Due Diligence Guidance for Responsible Supply Chains has become a global reference framework, underpinning legislation in the US, EU, and Switzerland. In addition, the Responsible Minerals Initiative (RMI) has developed widely adopted, standardized reporting frameworks, most notably the Conflict Minerals Reporting Template (CMRT) and the Extended Minerals Reporting Template (EMRT).
For companies, conducting due diligence on critical minerals is no longer just a regulatory obligation. It’s a strategic imperative to strengthen supply chain resilience, meet stakeholder expectations, and protect long-term brand value.
The IntegrityNext Solution
IntegrityNext enables companies to perform efficient due diligence through standardized supplier assessments and AI-powered supply chain transparency – providing deep insights from raw material sourcing to final product assembly.
Streamlined Conflict Minerals Assessment
- Suppliers indicate whether they manufacture or distribute products containing critical minerals.
- Easily collect completed CMRT (for 3TG) and EMRT (for cobalt, mica, copper, natural graphite, lithium, and nickel) reporting templates directly on the IntegrityNext platform.
- Obtain visibility into smelters and refiners in your supply chain to identify risks.
Automated Screening and Validation
The platform automatically checks uploaded CMRTs and EMRTs for:
- Form completeness – ensuring all required fields are filled out.
- Smelter risks – highlighting whether smelters are active or conformant.
- Supplier due diligence – assessing responsible sourcing policies, corrective actions, and audit expectations for sub-suppliers.
Centralized Data Insights and Reporting
- Automatically consolidate supplier data into aggregated CMRTs.
- Flag suppliers linked to non-conformant and inactive smelters for targeted follow-up.
- Export reports for full compliance with regulatory requirements in the US, EU, and Switzerland.
Supplier Engagement and Continuous Improvement
- Leverage built-in tools to facilitate supplier collaboration and engagement.
- Provide supplier guidance on assessments and responsible sourcing practices through the IntegrityNext Academy.
- Work toward long-term goals – such as shifting suppliers to RMI-active, conformant smelters in high-risk regions.
Enhanced Supply Chain Transparency
- Map your supply chain end-to-end, from raw material extraction to finished product.
- Identify conflict minerals exposure across all tiers – including associated human rights and environmental risks.
- Engage with suppliers to drive risk mitigation and sustainable sourcing practices.
With IntegrityNext, you get the tools and insights you need to turn mineral due diligence from a compliance task into a strategic advantage.
Efficient Compliance with Due Diligence Legislation
Request a demo and see how our platform streamlines supply chain due diligence on conflict and high-risk minerals. Identify risks across all tiers, engage your suppliers, and take targeted action to ensure responsible sourcing.
Key Challenges for Companies
Managing conflict and high-risk minerals presents significant challenges:
Opaque, multi-tier supply chains with limited visibility beyond tier 1.
Low-quality or incomplete supplier data provided in reporting templates.
Difficult risk verification when smelters and refiners are not active or conformant.
High-risk sourcing regions marked by weak governance, corruption, and security issues.
Resource constraints, especially among smaller suppliers with limited capacity.
Fragmented regulatory frameworks with differing obligations and scopes across jurisdictions.
Expanding scope of due diligence requirements, covering minerals such as copper, natural graphite, lithium, and nickel.
Benefits of the IntegrityNext Solution at a Glance
- Immediate access to thousands of completed CMRT and EMRT templates – accelerating compliance and reducing supplier workload.
- Automated supplier reporting completeness checks to ensure comprehensive and reliable disclosures.
- Efficiency gains through streamlined supplier assessments, process automation, and consolidated reporting.
- Enhanced visibility into smelters, refiners, and sourcing origins.
- Multi-tier transparency for deep supply chain insights beyond tier 1.
- Extensive supplier support and capacity building via a dedicated learning platform.
- Supply chain resilience built on targeted risk identification and proactive management.
- Full compliance with regulatory requirements on 3TG in the US, EU, and Switzerland.
- Readiness for evolving regulatory requirements, including emerging legislation covering additional high-risk minerals.
Regulatory Landscape on Conflict Minerals
Several countries have introduced due diligence legislation specifically targeting 3TG conflict minerals. These regulations require companies to conduct and report on due diligence in accordance with the five-step risk management framework of the OECD.
US Dodd-Frank Act, Section 1502
- Applies to SEC-listed companies that manufacture or contract to manufacture products requiring 3TG for functionality or production.
- Focuses on the Democratic Republic of the Congo (DRC) and adjoining countries.
EU Conflict Minerals Regulation
- Applies to EU importers of 3TG above certain mass thresholds, covering both upstream and downstream actors.
- Covers all Conflict-Affected and High-Risk Areas (CAHRAs) worldwide, not just the DRC region.
- Applies to all types of batteries – including portable, industrial, and automotive – and covers cobalt, lithium, nickel, natural graphite, and 3TG.
- Aims to ensure sustainability, safety, circularity, and due diligence across the entire battery lifecycle.
- Applies to Swiss companies that import or process 3TG above established thresholds.
- Imposes additional due diligence obligations for child labor, making it broader in scope than US and EU conflict mineral frameworks.
While traditional conflict minerals legislation focuses on 3TG, an increasing number of high-risk minerals now fall under broader human rights and environmental due diligence laws, including the German Supply Chain Act (LkSG), the French Duty of Vigilance Law, and the EU Corporate Sustainability Due Diligence Directive (CSDDD).
These initiatives mark a significant shift toward comprehensive corporate accountability in global supply chains.
Turning Transparency into a Competitive Advantage
Discover how our platform gives you complete visibility into mineral sourcing, helps you identify high-risk suppliers, and ensures responsible, traceable supply chains.
What Are Common Conflict Minerals?
Under current legislation, only four minerals – tin, tantalum, tungsten, and gold (3TG) – are classified as conflict minerals. They are critical inputs for a wide range of industries, but their extraction is often linked to serious social and environmental concerns.
Tin
Used in: Soldering for electronics, coatings, alloys, and glass production
Major producers: China, Indonesia, Myanmar, and Central Africa
Key challenges: Links to armed conflict and human rights abuses, illegal mining, deforestation, and pollution from artisanal operations.
Tantalum
Used in: Capacitors for electronics, medical devices, and aerospace superalloys
Major producers: Democratic Republic of the Congo (DRC), Rwanda, Australia, and Brazil
Key challenges: Financing of armed conflicts, poor working conditions in artisanal mining, and child labor risks
Tungsten
Used in: Hard metals for cutting tools, mining equipment, and electronics
Major producers: China, with smaller volumes from Central Africa, Russia, and Bolivia
Key challenges: Financing of armed conflicts, unsafe artisanal mining, and high energy use in refining
Gold
Used in: Jewelry, electronics, and aerospace applications
Major producers: China, Australia, Russia, Canada, and artisanal mines across Africa and Latin America
Key challenges: Financing of armed conflicts, child labor, unsafe working conditions, environmental pollution, and deforestation
Beyond 3TG: Other High-Risk Minerals
Several other minerals – including cobalt, mica, copper, natural graphite, lithium, and nickel – pose sustainability and human rights challenges similar to those associated with 3TG. They increasingly fall under emerging regulatory mandates such as the EU Batteries Regulation and broader due diligence frameworks – making the case for holistic risk management approaches.
Cobalt
Used in: Rechargeable batteries, aerospace superalloys, and catalysts
Major producers: DRC (dominant), Australia, Canada, and Russia
Key challenges: Unsafe artisanal mining, child labor, corruption, and environmental impacts such as water pollution and habitat destruction
Copper
Used in: Wiring, electronics, renewable energy infrastructure, and electric vehicles
Major producers: Chile and Peru, with additional mining in China, the DRC, and the US
Key challenges: Deforestation, high water use in arid regions, tailings dam failures, acid mine drainage, and social conflicts over land and water rights
Lithium
Used in: EV and energy storage batteries, glass, ceramics, and lubricants
Major producers: Chile, Argentina, Bolivia (brine extraction), and Australia (hard rock mining)
Key challenges: High water consumption in arid regions, land and water rights conflicts, and biodiversity concerns
Mica
Used in: Electronics, cosmetics, and automotive manufacturing
Major producers: India, Madagascar, and China
Key challenges: Child labor, unsafe and unregulated mining, worker exploitation, and environmental degradation
Natural graphite
Used in: Lithium-ion batteries, lubricants, refractories, and pencils
Major producers: China, Mozambique, Madagascar, and India
Key challenges: Environmental pollution, supply chain opacity, and land-use conflicts
Nickel
Used in: Stainless steel, metal alloys, and increasingly as a battery cathode material
Major producers: Indonesia, the Philippines, Russia, Canada, and Australia
Key challenges: Deforestation, biodiversity loss, emissions from energy-intensive processing, and tailings management risks
Book a demo
Strengthen due diligence across your minerals supply chains with IntegrityNext. Collect supplier data, identify and manage risks - for smarter, more responsible sourcing.
- Ensure compliance with US, EU, and Swiss legislation
- Uphold international due diligence standards
- Take effective action in collaboration with your suppliers
- Map your supply chains down to lower tiers and identify critical risks
FAQs – Common Questions About Conflict and High-Risk Minerals
Do cobalt, mica, and other high-risk minerals count as conflict minerals?
Legally, no. Under current regulations such as the U.S. Dodd-Frank Act and the EU Conflict Minerals Regulation, only tin, tantalum, tungsten, and gold (3TG) are defined as conflict minerals. However, in practice, companies increasingly apply the same due diligence principles to cobalt, mica, and other high-risk minerals because they carry significant human rights and environmental risks. These efforts are supported by the RMI’s Extended Minerals Reporting Template (EMRT).
What are “conflict-affected and high-risk areas” (CAHRAs)?
CAHRAs are regions where mineral extraction is linked to armed conflict, weak governance, human rights abuses, or corruption. The EU Conflict Minerals Regulation requires companies to identify and manage risks if they source from such areas.
Why is supplier engagement so challenging in conflict mineral due diligence?
Many suppliers operate far upstream in the supply chain or lack the resources to complete reporting templates accurately. Companies often struggle with incomplete data, inactive smelters, or suppliers who are unfamiliar with international due diligence standards.
What is the role of reporting templates such as the CMRT and EMRT?
The Conflict Minerals Reporting Template (CMRT) and the Extended Minerals Reporting Template (EMRT) are standardized tools developed by the Responsible Minerals Initiative (RMI). They help companies collect consistent supplier data, trace sourcing origins, and simplify regulatory reporting.
What is the Responsible Minerals Assurance Process (RMAP) and why is it important?
The RMAP, developed by the RMI, is an independent third-party audit program that assesses smelters and refiners of 3TG and other high-risk minerals. It verifies whether these facilities implement robust due diligence practices and source responsibly. For companies, relying on RMAP-conformant smelters provides assurance, simplifies reporting, and reduces the risk of being linked to human rights abuses or the financing of armed conflicts.
What are active and conformant smelters?
Active smelters are those participating in the RMAP of the RMI. They are either undergoing an audit or scheduled for an audit in the near future. Conformant smelters have successfully passed an RMAP audit and meet the RMI's standards for responsible sourcing.
How can companies go beyond compliance?
Beyond meeting legal requirements, companies can strengthen supply chain resilience by investing in supplier training and capacity building, supporting responsible sourcing programs, participating in industry initiatives, and integrating ESG data into procurement decisions.