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On 15 June 2016, EU institutions agreed on a framework for an EU Regulation designed to ensure that minerals entering the EU have been sourced responsibly and without funding conflict and human rights abuses. This will build upon the OECD Due Diligence Guidance for responsible mineral sourcing (available here). The proposed Regulation will apply to the vast majority of metals and minerals imported to the EU will be covered, although small volume importers will be exempted. The agreed framework carries obligations for the upstream part of the conflict minerals supply chain to source raw metals and raw minerals responsibly and to check the origin of materials they buy. The Commission will carry out additional measures (e.g., develop reporting tools) to strengthen due diligence by large and smaller EU downstream companies using such metals and minerals as components in goods. Negotiations on technical implementation are expected to last several months. Ross Denton and Sunny Mann of our London office authored the above. For updates, please check our Sanctions blog.
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