What are conflict minerals?

Minerals mined from areas of conflict like the Republic of Congo. These minerals must be avoided in every downstream and upstream manufacturing company. There are four minerals codified in the US Conflict Minerals Law and are commonly termed as 3TG. Tantalum, Tine, Tungsten and Gold. According to the Dodd–Frank Wall Street Reform and Consumer Protection Act, companies have to submit an annual conflict minerals report to the SEC.

Challenges businesses face with Conflict Minerals Compliance

  • Identifying Substitutes for 3TG Minerals
  • Deficiencies in Tracing
  • Insufficient Documentation
  • Locating Ethical Smelters and Refiners
  • Due Diligence in Supply Chains

Conflict Minerals in the US and Europe (Table)

Tin (Sn): Used in electronic components, solder, and other applications.

Tantalum (Ta): Found in electronic capacitors, aerospace components, and other devices.

Tungsten (W): Utilized in electronics, machinery, and industrial applications.

Gold (Au): Widely used in jewelry, electronics, and various industrial processes.

The US and European regulations aim to ensure responsible sourcing and prevent the use of conflict minerals in supply chains. These regulations apply to companies that trade on US exchanges and to importers of the targeted minerals established in the European Union.

Conflict Minerals Services from Horiaki

Consultation Services and Formulation of Strategic Approaches

Plan to Ensure Compliance with Conflict Minerals Regulations

Compliance Reporting and Documentation

Rigorous Evaluation of Supply Chain to Ensure Due Diligence

What does Horiaki bring you as a partner?

Comprehensive evaluations of CMRT and CRT.

Evaluation, analysis, and documentation of compliance data.

Acquire conflict minerals data from the supply chain.

Support customers in determining the Reasonable Country of Origin (RCOI).

Prepare conflict minerals reports for submission to customers or the SEC.

Exceptional solution at affordable pricing


The Conflict Minerals Reporting Template (CMRT), established by the Responsible Minerals Initiative (RMI), is a standardized reporting template designed to facilitate the efficient exchange of information concerning mineral country of origin and the relevant smelters and refiners.

The major countries falling within the conflict-affected regions comprise the Democratic Republic of the Congo, Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

The Dodd-Frank Act, which was signed into law in 2010, is a comprehensive regulatory framework known as the Dodd-Frank Wall Street Reform and Consumer Protection Act. It was introduced during the Obama administration to address the causes of the 2008 financial crisis and prevent future economic turmoil.

There are no legal restrictions on sourcing conflict minerals from the DRC and the adjoining countries, provided that the smelters in the supply chain do not possess RMI certification.

Even if the products do not contain any 3TG minerals, it is mandatory to provide the CMRT to the customer. In the “declaration” tab, the response should be marked as “No” to indicate that 3TG is not utilized in the products.

The SEC plays a crucial role in monitoring the compliance of businesses with conflict minerals regulations, ensuring that the entire process is conducted legally.

The Responsible Business Alliance (RBA) has designed the Cobalt Reporting Template (CRT) as a standardized reporting template that enables the seamless transfer of information concerning cobalt mineral origin and the smelters and refiners associated with it.

Embrace Responsible Sourcing Practices.