The EU Conflict Minerals Regulation (Regulation 2017/821) establishes due diligence obligations for EU importers of tin, tantalum, tungsten, and gold (3TG) from conflict-affected and high-risk areas (CAHRAs). Cobalt is not currently within the regulation's scope, but it is under active review by the European Commission as part of the Critical Raw Materials Act (CRMA) framework.
Current Scope: 3TG Minerals
The regulation applies to EU importers of 3TG minerals and metals above defined volume thresholds. It requires importers to implement OECD-aligned due diligence covering supply chain mapping, risk assessment, risk mitigation, third-party audits, and annual reporting. The regulation has been in full effect since January 2021.
Cobalt Under Review
The European Commission's 2023 Critical Raw Materials Act identified cobalt as a strategic raw material with significant supply chain risk. The Commission is conducting a review of whether cobalt should be added to the Conflict Minerals Regulation scope, given the DRC's status as both the dominant cobalt producer and a conflict-affected area under OECD definitions.
Practical Implications for Cobalt Supply Chains
Even though cobalt is not currently within the regulation's formal scope, many EU importers apply 3TG-equivalent due diligence to cobalt as a matter of best practice and in anticipation of regulatory expansion. The EU Battery Regulation's due diligence requirements (Articles 48–52) effectively create 3TG-equivalent obligations for cobalt in battery supply chains from August 2025.
Responsible Minerals Initiative (RMI)
The RMI's Cobalt Refiner Assessment Program (CoRAP) is the primary third-party audit program for cobalt refiners. CoRAP-conformant refiners have undergone independent audits against OECD due diligence standards. Sourcing from CoRAP-conformant refiners is the primary mechanism for demonstrating compliance with both the EU Battery Regulation and voluntary 3TG-equivalent standards.