The EU Conflict Minerals Regulation: Challenges for Achieving Mineral Supply Chain Due Diligence - By Daniel Iglesias Márquez

Editor’s note: Daniel Iglesias Márquez is an external researcher in Business and Human Rights at the Tarragona Centre for Environmental Law Studies. He holds a PhD from the Rovira Virgili University in Tarragona (Spain). Other main fields of interest include International Environmental Law, International Criminal Law and European law.


The EU and its Member States have largely endorsed the UN Guiding Principles on Business and Human Rights (UNGPs) in their Corporate Social Responsibility (CSR) strategy and have committed to supporting their implementation.[i] The UNGPs state that companies have a responsibility to respect human rights wherever they operate. Companies are therefore expected to take proactive steps to ensure that they do not cause or contribute to human rights abuses within their global operations and to respond to human rights abuses when they do occur. This implies establishing due diligence processes to identify, prevent, mitigate and record potential and actual adverse human rights impacts.

Although the EU has not played a constructive role at the Geneva negotiations for a UN Treaty on business and human rights,[ii] some modest developments in the right direction have been made at the EU level to foster a culture of ‘doing business right’ among companies in certain industrial sectors. Put differently, the EU has adopted regulations and directives that implement the UNGPs.

Due diligence requirements are the most common way of ensuring that business behavior meets social expectations. An example of this is the new EU Conflict Minerals Regulation (Regulation),[iii] which requires EU companies to ensure the responsible sourcing of minerals and metals. This EU law has an extraterritorial reach since due diligence requirements must be exercised by a company throughout its international supply chain. However, the Regulation raises a number of challenges ahead that may affect its purpose and implementation. More...