The EU Regulation on the responsible supply of tin, tungsten, tantalum and gold (3TG) originating from conflict-affected and high-risk areas (CAHRAs) came into full force on 1 January 2021. Also known as the “Conflict Minerals” or “Responsible Minerals” Regulation, it aims to break the link between the exploitation and trade in 3TG on the one hand, and conflict financing on the other hand. The law also aims to support the development of local communities.
Disappointingly, more than six years after the Regulation was signed into law, and almost three years after the requirements for EU importers started applying, our overall assessment is that the Regulation has not achieved any notable impact along supply chains, let alone in producing countries. At the same time, the illegal trade of minerals, in particular gold, continues to play an important role in financing certain conflicts, alongside other revenue streams.