Conflict Minerals Legislation Coming to the EU
According to this Reuters article and a blog by Elm Sustainability Partners LLC, an informal deal for EU conflict minerals legislation has been reached. The final text will be voted on by the member states on December 7, 2016, with a vote in the plenary expected in the first half of 2017. The regulation would become effective in 2021.
Although OECD guidelines will be used, the structure is much different than the United States. Only importers of tin, tungsten, tantalum, gold and their ores are covered. The legislation does not reach manufactured products on a mandatory basis.
The legislation will apply to companies with more than 500 employees but small volume importers will be exempt from these obligations. Reports indicate dentists and jewelers are exempt.
According to this report, large manufacturers will be encouraged to voluntarily report on their “due diligence” and sourcing practices using new performance indicators. They will also be encouraged to join an EU registry, designed to track mineral sourcing policies.
However, a review clause included in the regulation means mandatory measures could be brought in if the voluntary measures prove too be having too limited an impact, with reviews set to take place two years after the start of the new law and then every three years thereafter.
Contact Steve Quinlivan for more information.