At long last, the EU Conflict Minerals Regulation was published today in the Official Journal of the European Union. The EU Conflict Minerals Regulation 2017 (as published) will enter into force 20 days after publication (June 8, 2017) and take effect 1 month after that (July 8, 2017).
The effective date is January 2021, but companies would be wise to start thinking about how the regulation will impact them. There are some significant consequences for importers that deal with non-compliant smelters or refiners — including required consultations and third-party audits. These consultations and audits will be time-consuming and expensive. So, importers will be motivated to manage their supply chains so that they can avoid these additional burdens. Those who have been working on conflict minerals compliance under the US rule know that it takes some time to examine and successfully manage the make-up of a company’s supply chains. So, don’t wait to examine this final regulation more closely.