Conflict Minerals: The Dark Side of Your Smartphone Explained

Picture a smartphone in your hand. Behind its screen lies a story of conflict, exploitation and environmental damage that begins with four minerals: gold, tin, tungsten and tantalum.

What are conflict minerals and where do they come from?

They are minerals mined in conflict-affected or high-risk areas where their trade funds violence. The focus is the DRC and its neighbours. The US Dodd-Frank rules cover the DRC and adjoining countries, including Angola, Burundi, the Central African Republic, the Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda and Zambia. Sudan and Zimbabwe, named in older versions of this post, are not among the covered countries.

Miners often work in dangerous conditions, long hours and exposure to harmful substances. Eastern DRC shows the stakes. The Rubaya mine, which supplies around 15% of the world’s tantalum, has been under M23 control since 2024, and a landslide and collapse at Rubaya at the end of January 2026 killed more than 200 people.

What is the real cost for people and nature?

Environmental damage: uncontrolled mining clears forest, contaminates soil and groundwater, and destroys habitats.

• Forest loss to make way for mines harms biodiversity and disrupts ecosystems for generations.
• Toxic chemicals can contaminate water and soil for years.
• Unique ecosystems can be lost permanently.

Human cost: behind the statistics are children working in mines instead of attending school, families forced off their land, and communities living under the control of armed groups. Fatal accidents are a constant risk in artisanal mines.

Which laws apply in the EU, Germany, the UK, the US and Canada?

The rules differ, and they are narrower than many people think:

• EU: Regulation (EU) 2017/821 requires EU importers of 3TG above set volume thresholds to carry out supply chain due diligence following the OECD Due Diligence Guidance. It applied from January 1, 2021. The first Commission review was published on September 24, 2024, and the 2027 review will focus on implementation, enforcement and easing the burden on businesses, especially SMEs, without changing the reporting requirements.
• Germany: the Mineralische-Rohstoffe-Sorgfaltspflichten-Gesetz (MinRohSorgG) implements the EU regulation, and the federal geosciences agency BGR is the competent authority. Germany’s Lieferkettensorgfaltspflichtengesetz (LkSG) adds broader human rights due diligence, with the annual report to BAFA abolished retroactively from January 1, 2023.
• UK: there is no 3TG-specific law, but large companies must publish a slavery and human trafficking statement under section 54 of the Modern Slavery Act 2015.
• US: Section 1502 of the Dodd-Frank Act requires companies that file with the SEC and use 3TG to disclose origin checks on Form SD.
• Canada: the Fighting Against Forced Labour and Child Labour in Supply Chains Act (S-211) requires covered entities to report annually on forced and child labour risks.

The EU CSDDD adds general due diligence, but after Omnibus I it only covers companies with over 5,000 employees and EUR 1.5 billion turnover, from July 26, 2029. For battery supply chains, see the EU Battery Regulation in our guide on conflict minerals and CSDDD due diligence.

Are the rules working?

Progress is real, but enforcement gaps remain. Companies now map suppliers, use the Responsible Minerals Initiative’s smelter audit programme and track tin, tungsten and tantalum through schemes such as ITSCI. At the same time, UN experts and NGOs report that minerals from M23-controlled areas are smuggled to Rwanda and mixed with other supply. A 2025 Global Witness investigation alleged that a European trader bought coltan smuggled from conflict zones, which the trader denied. The EU Parliament and civil society have also criticised the EU’s raw materials agreement with Rwanda. The DRC filed a criminal complaint against Apple in 2024, and Apple has said it told suppliers to stop buying minerals from the DRC and Rwanda. These cases show that certification schemes need independent verification.

• Electronics recycling reduces demand for newly mined 3TG.
• Traceability tools, including blockchain pilots, can help, though they cannot prove that entered data is true. See our post on blockchain in sustainability reporting.
• Independent audits of smelters and mine-site checks give stronger assurance than paperwork.

What can you do?

Consumers and businesses both have levers:

1. Check how your electronics supplier reports on conflict minerals and responsible sourcing.
2. Support companies with demonstrably audited supply chains.
3. Use devices longer, repair them and recycle them properly.
4. If you buy or import 3TG, map your suppliers and follow the OECD guidance.
5. Support organisations that work on fair working conditions and push for strong enforcement.

Remember: every purchase and sourcing decision shapes the technology future we get.

Frequently Asked Questions

What are the four conflict minerals?

Tin, tantalum, tungsten and gold, often called 3TG. They are used in electronics, aerospace, automotive parts and jewellery.

Is it illegal to use conflict minerals?

Not in itself. EU importers must carry out due diligence, and US SEC filers must disclose their checks. The laws are about transparency and process, not a ban, and they apply to specific companies above set thresholds.

When is the EU conflict minerals regulation being reviewed again?

The Commission must review the regulation every three years. The first review report came out on September 24, 2024, and the next one is planned for 2027, focused on enforcement and on easing the burden for SMEs.