
RESPONSIBLE SOURCING
Ensure Responsible Sourcing with Confidence
Stay Responsible. Stay Trusted.
Meeting today´s regulatory and ethical standards for responsible sourcing is more important than ever.
CDX makes this process straightforward by bringing together all your sourcing data - covering conflict minerals (3TG: tin, tungsten, tantalum, and gold) and extended minerals like cobalt and mica - so you can quickly identify risks and stay compliant.
With CDX, you benefit from centralized information, in-depth smelter analysis, and robust quality checks. This not only helps you avoid non-compliance, but also builds resilience, transparency, and trust across your supply chain - while keeping your intellectual property secure.
Explore our scope of responsible sourcing regulations
to find detailed guidance tailored to your needs
to find detailed guidance tailored to your needs

Responsible Minerals Reporting
Take control of your conflict minerals compliance with our Responsible Minerals Reporting solution. Designed for regulatory frameworks like the EU Conflict Minerals Regulation and the U.S. Dodd-Frank Act, CDX empowers your team to meet due diligence requirements and drive sustainable sourcing.
- Simplify Conflict Minerals Declaration (CMD) management
- Expand reporting with the Extended Minerals Declaration (EMD)
- Ensure traceability with centralized smelter validation
CDX Features for Conflict Minerals
Conflict Minerals: What You Need to Know
What are conflict minerals, and why are they regulated?
Conflict minerals refer to tin, tungsten, tantalum, and gold (3TG), which are often mined in regions affected by armed conflict, human rights abuses, and environmental harm. These minerals can finance violence and exploitation, particularly in areas like Democratic Republic of Congo (DRC). As a result, governments and international bodies have introduced regulations to ensure companies source these minerals responsibly, aiming to cut financial support for conflict and promote ethical supply chains.
What are the main legal requirements for conflict minerals in the European Union?
The EU Conflict Minerals Regulation (Regulation (EU) 2017/821), effective since January 1, 2021, requires EU importers of 3TG minerals and metals to conduct due diligence on their supply chains. This includes establishing supply chain policies, assessing risks, implementing strategies to address those risks, conducting independent third-party audits (for smelters and refiners), and publicly reporting on due diligence practices. The regulation applies to all conflict-affected and high-risk areas globally, not just Central Africa, and is enforced by EU Member States.
What are the main legal requirements for conflict minerals in the United States?
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires US-listed companies to determine if 3TG minerals are necessary to their products. If so, companies must conduct a reasonable country of origin inquiry to see if these minerals originated in the Democratic Republic of Congo or neighboring countries. If the minerals are found to originate from these regions or their origin is uncertain, companies must perform due diligence, file an annual Specialized Disclosure Report (Form SD) with the SEC, and disclose their due diligence efforts. The rule is enforced by the SEC and focuses on transparency and public reporting.
How do the EU and US regulations differ in their approach and scope?
The EU regulation applies to all conflict-affected and high-risk areas worldwide and targets upstream importers of 3TG minerals and metals. It emphasizes due diligence, risk assessment, and public disclosure, with enforcement handled by individual EU Member States.
The US regulation, by contrast, specifically targets the DRC and adjoining countries and applies to downstream manufacturers and contract manufacturers who are publicly listed in the US. It requires annual public reporting to the SEC and focuses on transparency regarding sourcing practices.
What practical steps must companies take to comply with these regulations?
Companies must integrate due diligence into procurement and sourcing policies, engage with suppliers through training and contractual requirements, and invest in systems for supply chain mapping and risk assessment. They often use industry-standard tools like the Conflict Minerals Reporting Template (CMRT) to collect and validate supplier data. Regular audits, transparent reporting, and participation in shared industry initiatives also support compliance.
What are the consequences of non-compliance with conflict minerals regulations?
Non-compliance can result in legal penalties, exclusion from key markets, reputational damage, and loss of customer or investor trust. Companies may also face supply chain disruptions if they cannot demonstrate responsible sourcing, and they risk being excluded from tenders or long-term contracts with customers who require proof of compliance.
How do these regulations impact broader business strategy and supply chain management?
Compliance with conflict minerals regulations encourages companies to improve supply chain transparency, invest in digital tracking systems, and build stronger supplier relationships. It also aligns with broader ESG and corporate social responsibility goals, helping companies manage risk, enhance brand value, and meet growing expectations from customers, investors, and regulators for ethical business practices.
CDX Features for Cobald & Mica
Cobald & Mica: What You Need to Know
How does the EMRT help companies beyond regulatory compliance?
The EMRT is more than a compliance tool. It enables companies to map and understand their extended minerals supply chain. With the EMRT, organizations can proactively identify vulnerabilities, anticipate supply disruptions, and align sourcing strategies with ESG and sustainability goals. This data-driven approach informs procurement and strengthens supplier relationships.
Why are cobalt and mica considered high-priority minerals for responsible sourcing?
Cobalt and mica are under scrutiny due to risks of child labor, unsafe conditions, and environmental harm, especially in artisanal mining. Their inclusion in the EMRT reflects growing pressure from regulators, customers, and investors to address these issues and promote responsible sourcing.
What impact does cobalt and mica reporting have on downstream industries?
Industries like automotive, electronics, and cosmetics now face higher expectations for ethical sourcing. This affects supplier selection, contracts, and even product design, as companies work to avoid reputational and operational risks.
Are there other business benefits to collecting and analyzing cobalt and mica data?
Yes. Robust data can reveal supply chain optimization opportunities, cost savings, and innovation potential. Companies may identify more reliable suppliers, material substitutions, or use responsible sourcing credentials in marketing and investor relations.
How can responsible cobalt and mica sourcing become a competitive advantage?
Companies that lead in responsible sourcing can secure preferred supplier status, enter new markets, and build stronger brand loyalty. Transparent reporting can also be decisive in B2B partnerships as ESG criteria become central to procurement.
What are the main obstacles in cobalt and mica due diligence?
Challenges include data gaps, inconsistent supplier engagement, and evolving expectations. Solutions include digital platforms like CDX for data management, supplier training, and industry collaboration to harmonize standards.
How might global rules on cobalt and mica evolve?
Expect more scrutiny, detailed reporting, and greater integration into ESG disclosures. Early adoption of robust due diligence helps companies adapt quickly, shape industry standards, and maintain a leadership position.
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