Scope of the Regulation (EU) 2017/821

The regulation establishes the obligation to apply due diligence for importers who supply minerals and metals from conflict-affected and high-risk areas.
These are 23 minerals and metals listed in Annex I of the regulation whose annual imports exceed the established volume thresholds.

Link: Annex I amended by Commission Delegated Regulation (EU) 2020/1588 of 25 June 2020

Timing of application and implementation of the Regulation (EU) 2017/821

From January 1, 2021, the Due Diligence becomes mandatory for the import of minerals and metals indicated in Annex I of the regulation enters into force.
On January 1, 2022, the ex post checks carried out by the National Competent Authority will begin to verify the effective adoption of Due Diligence.
A first review of the EU regulation is expected in 2023, and includes an analysis of the impact of the regulation on the economic operators involved, including small and medium-sized enterprises.

Obligations deriving from the Regulation and companies potentially subject to ex-post checks

Due diligence obligations apply to EU importers as of January 1, 2021.
Pursuant to Article 11 of the regulation, the following importers are subject to ex post checks:
- importers falling within the scope of the Regulation
- importers participating in recognized due diligence schemes
- importers sourcing from responsible global smelters and refineries, which appear on the Commission list referred to in Article 9 (5) of the Regulation

Upstream companies
The supply chain of minerals from mining sites to smelters and refineries, such as mineral producers, commodity traders, smelters and refineries.
Downstream companies
The metal supply chain from the next stage through foundries and refineries to the final product, e.g. traders, component manufacturers, manufacturers.

Link: Conflict Minerals Regulation explained - Trade - European Commission ( 

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