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Konfliktmineralien
In brief
Conflict minerals are raw materials whose extraction or trade in conflict and high-risk areas may finance armed groups or be linked to serious human rights violations. In EU law, this refers to tin, tantalum, tungsten, their ores, and gold. Conflict minerals are relevant for IT hardware because all four substances are found in electronics – and because every device that is reused reduces the demand for newly mined raw materials.
What rules apply to conflict minerals? (As of: 10/2026)
EU Regulation (EU) 2017/821 has applied since January 1, 2021. It obliges companies that import tin, tantalum, tungsten, their ores or gold above certain volume thresholds into the EU to carry out due diligence in their supply chain. It is based on the OECD guidelines. In Germany, the Mineral Raw Materials Due Diligence Act regulates implementation; the competent authority is the German Control Office for EU Due Diligence in Raw Material Supply Chains (DEKSOR) at the Federal Institute for Geosciences and Natural Resources. In the USA, Section 1502 of the Dodd-Frank Act imposes its own reporting obligation. The regulation covers importers of the raw materials and metals, not the manufacturers of finished devices. These are nevertheless affected through their supply chains. This entry does not replace legal advice.
Conflict minerals in IT hardware
| Raw material | Typical use in electronics |
|---|---|
| Tin | Solder on circuit boards |
| Tantalum | Capacitors |
| Tungsten | e.g. vibration motors in smartphones |
| Gold | Contacts and connections |
When purchasing, companies can look for manufacturer statements on due diligence in the supply chain. At the end of the lifecycle, what counts is to keep using devices for as long as possible and to recover raw materials, see Precious metal recovery and critical raw materials. Further background is provided by the article 10 Surprising Facts About E-Waste. Second IT prepares decommissioned devices for reuse and recovers materials such as precious metals from devices that can no longer be used.
Frequently asked questions about conflict minerals
Which raw materials count as conflict minerals?
Under EU law, tin, tantalum and tungsten, their ores, and gold. In English, they are often referred to as 3TG.
Does the EU regulation apply to companies that buy computers?
No, importers of the raw materials and metals above certain volumes are directly obliged. However, buyers of IT hardware can demand supply chain evidence in their procurement.
How does reusing IT devices help?
Every device that is used longer or resold replaces a newly produced one and thus also newly mined raw materials.
What are conflict minerals used for in electronics?
Tin serves as solder on circuit boards, tantalum is found in capacitors. Tungsten is found, for example, in the vibration motors of smartphones, gold in contacts and connections. All four substances are therefore contained in IT hardware.
Who monitors due diligence obligations for conflict minerals in Germany?
The competent authority is the German Control Office for EU Due Diligence in Raw Material Supply Chains (DEKSOR) at the Federal Institute for Geosciences and Natural Resources. The basis is the EU regulation, the German implementing act and the OECD guidelines.
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