What are conflict minerals and why are they important in 2025?

Conflict minerals include tin, tungsten, tantalum, and gold (3TGs). Many companies also have responsible sourcing programs for cobalt, lithium, and mica. In 2025, due to rising global conflicts and new sanctions, sourcing these minerals responsibly is more critical than ever to avoid non-compliance and supply chain risks.

What’s new in conflict minerals compliance for 2025?

Key updates include increased conflict in the eastern Democratic Republic of the Congo (DRC), new sanctioned smelters, and the addition of an RMAP-compliant smelter to the UFLPA Entity List. Companies need RCOI data, not just smelter compliance, to stay ahead.

What is RCOI and why is it essential for compliance?

RCOI stands for Reasonable Country of Origin Inquiry. It ensures companies trace minerals back to their source, not just the smelter. In 2025, RCOI data is crucial to meeting legal requirements and avoiding hidden compliance risks.

What is the CMRT and how is it used?

The Conflict Minerals Reporting Template (CMRT) is a standardized form used to gather data on 3TG minerals from suppliers. It helps companies comply with regulations like the Dodd-Frank Act by identifying smelters and countries of origin.

How can companies build a strong conflict minerals compliance program?

Companies should perform a scope analysis, create a clear compliance plan, collect accurate supplier data using the CMRT, and monitor regulatory updates. Tools like Assent’s solution support reporting, smelter risk assessment, and RCOI data collection.

What is changing with REACH regulations regarding hexavalent chromium (CrVI)?

The European Chemicals Agency (ECHA) is expected to move multiple CrVI substances (already classified as REACH SVHCs) from the REACH Authorisation List to the REACH Restricted Substances List (Annex XVII). This means that substances like chromium trioxide, chromic acid, and 12 additional CrVI compounds will no longer require prior approval but will instead be banned from use in products and parts in the EU market. A restriction proposal is expected by April 11, 2025.

Why is REACH moving CrVI from authorization to restriction?

The current REACH authorization process has failed to keep up with the high volume of industry requests. Instead of the required three-month review period, CrVI authorization requests have taken an average of 14.5 months, leading to annulled decisions, compliance uncertainty, and supply chain disruptions. An EU ombudsman audit found procedural issues and data quality concerns, prompting calls for a more efficient, transparent process. This led to a full restriction as the preferred solution.

What will the new hexavalent chrome restriction cover?

The expected restriction will likely apply to articles containing CrVI compounds, especially those with components that may come into direct and prolonged contact with the skin. This would expand on the existing restriction under REACH Annex XVII, which currently prohibits leather articles containing CrVI at concentrations of 3 mg/kg (0.0003%) or higher. The new rule could significantly impact industries such as automotive, aerospace, and defense manufacturing.

How can manufacturers prepare for the CrVI REACH restriction?

Manufacturers should take proactive steps to ensure compliance before the restriction is finalized. This includes:Engaging suppliers to identify any CrVI usage in the supply chainExploring alternative materials and coatings to replace CrVI substancesMonitoring ECHA updates to stay ahead of compliance deadlinesImplementing a REACH compliance strategy to prevent costly disruptions