Term · Policy, Trade & Geopolitics
Conflict minerals
Tin, tantalum, tungsten and gold, and in some frameworks cobalt, sourced from regions where trade may finance armed conflict, triggering supply chain due diligence and disclosure duties.
- Also known as
- 3TG
- Type
- Term
- Domain
- Policy, Trade & Geopolitics, Environmental compliance
Notes
US disclosure duties come from Dodd-Frank Section 1502, with a parallel EU due diligence regulation for importers.
Overview
Conflict minerals are tin, tantalum, tungsten and gold, often shortened to 3TG, when they may come from areas where their mining or trade helps finance armed conflict, and the term also names the due diligence and disclosure rules built around them. Electronics and chip companies are affected because these metals reach their products through long chains of smelters, refiners and component makers. Some company programmes and frameworks extend the same approach to other minerals, such as cobalt, but the legal definitions in the United States and the European Union cover the four 3TG metals.
How it works
Two regimes set most of the obligations. In the United States, Section 1502 of the Dodd-Frank Act led the Securities and Exchange Commission to require companies that file reports with it, and whose products need 3TG to function or be made, to carry out a good-faith inquiry into the country of origin and disclose the result on Form SD. Where the minerals may come from the Democratic Republic of the Congo or adjoining countries, and are not from scrap or recycled sources, the company must carry out due diligence on source and chain of custody. Parts of the rule were later struck down in court on free speech grounds. In the European Union, Regulation (EU) 2017/821 has applied since 1 January 2021 and requires importers of these minerals and metals above set volumes to source responsibly from conflict-affected and high-risk areas.
In practice the work runs through the supply chain. Manufacturers send suppliers a questionnaire, most commonly the free Conflict Minerals Reporting Template (CMRT) from the Responsible Minerals Initiative, which collects the smelters and refiners used. Those facilities can then be checked against the initiative's assurance process. Both regimes point to the OECD due diligence guidance as the reference framework.
Examples
- A listed chip company preparing its Form SD conflict minerals disclosure for the SEC.
- An assembly and test supplier returning a completed CMRT listing the tin and gold smelters behind its solder and wire.
- An EU importer of tantalum checking its volumes against the thresholds of Regulation (EU) 2017/821.
- A responsible sourcing analyst asking a supplier to move away from a smelter that has not completed the RMI assurance process.
Why it matters
Sustainability and responsible sourcing staff, supplier quality engineers, procurement teams and investor relations groups handle conflict minerals work, since customers, regulators and investors often ask for it. In electronics, tantalum is used in capacitors and tin in solder, and gold appears in electronics and in some semiconductor manufacturing chemistry, so few hardware makers are untouched.
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Last reviewed . Written by The Semiconductor Hub editorial team. The full glossary