Orgalime’s position on a possible EU initiative on responsible sourcing of minerals originating from conflict-affected and high-risk areas

Published: 4 November 2013

Policies & Issues: Environment

In March 2013 the European Commission launched a public consultation focused on a possible EU initiative on responsible sourcing of minerals originating from conflict-affected and high-risk areas. The results of this consultation will be used to decide whether and how it would be possible to complement the existing initiatives for good governance in minerals mining with an EU initiative. 

Raw materials like minerals form the basis for all industrial production processes, and are therefore vital for the European engineering industry. Mineral resources, such as gold, tin, tantalum and tungsten, are key elements of some consumer products such as cell phones, personal computers, televisions and MP3 players. Further to this fact, Orgalime recognises a responsibility to ensure that products of our industry are responsibly manufactured by our suppliers. 

We are aware that in a few regions of the world, there is a risk that funds obtained from the extraction of raw materials could be used to finance armed conflicts. Greater awareness of the conflicts in these regions on the part of the public and end-use industries has already prompted some companies of the engineering industry, especially in the electronics sector, to investigate their supply chains and determine steps to promote socially responsible sourcing of specific minerals. 

Some companies, for instance, require that their suppliers take measures to comply with all applicable conflict minerals laws and regulations, and take measures to eliminate minerals originating from conflict-affected and high-risk areas from their products and components. In this respect, companies demand the use of conflict-free minerals through requirements under contractual law. For companies, this approach is enforceable, as they have direct control over the configuration of their contractual conditions. At the same time, a major contribution is therefore made towards being able to prevent the absorption of conflict minerals into the supply chain.

The engineering industry unreservedly supports the aim to severe the connection between the mining of minerals and the funding of armed conflict. However, with regard to implementation, there are numerous concerns about the already existing and possible future initiatives. For the above reasons we would like to comment on possible EU initiatives and solutions to the issue of responsible sourcing of minerals originating from conflict-affected and high-risk areas.

Related Position Papers

Eunomia study in support of developing Guidance for Extended Producer Responsibility (EPR) Schemes: Comments on modulation of producers’ financial contributions [12 March 2019]

Feedback on the usability of the taxonomy - Orgalim response [25 February 2019]

Orgalim response: Consultation by Technical Expert Group on Sustainable Finance [25 February 2019]

Orgalime response to consultation on RoHS Substance Review Methodology [21 December 2018]

Comments on Product and Organisational Environment Footprint methodologies (PEF/OEF) [19 December 2018]

Circular Economy: Resolving the interface between EU waste, product and chemicals policy [29 October 2018]

Strategy on long-term EU Greenhouse Gas (GHG) emissions reduction: Turning challenges into opportunities - The contribution of the European technology industries [10 October 2018]

The EU Plastics Strategy: An Opportunity to Build a Competitive European Market for Secondary Raw Materials [10 June 2018]

Roadmap for EU product policy: creating a market for circularity [4 June 2018]