EU formally recognises first supply chain due diligence scheme under the Conflict Minerals Regulation

On 16 October 2025, the European Commission adopted an Implementing Decision (EU) 2025/2071 recognising, for the first time, a supply chain due diligence scheme under Regulation (EU) 2017/821 (EU Conflict Minerals Regulation), namely the Responsible Minerals Assurance Process (RMAP), owned by the Responsible Minerals Initiative (RMI). This was accompanied by an FAQ. 

According to the Commission, this recognition should reduce administrative burden for importers and promote greater transparency and efficiency in mineral value chains. 

Key takeaways

• The RMAP scheme is granted recognition of equivalence with the requirements of the EU Conflict Minerals Regulation. 

• EU importers can now rely on the RMAP scheme to demonstrate compliance with their corresponding obligations under the EU Conflict Minerals Regulation.

• Recognition does not remove individual importer obligations under Articles 4–7 CMR, particularly for importers of metals and downstream operators outside the scheme’s scope.

• Additional scheme recognitions may follow.

Supply chain due diligence schemes in the EU Conflict Minerals Regulation

In a nutshell, the EU Conflict Minerals Regulation imposes risk-based due diligence obligations on natural and legal persons importing into the European Union tin, tantalum, tungsten and gold (collectively known as 3TG) sourced from “all conflict-affected areas and high-risk areas”, where imports exceed fixed annual threshold. These obligations include, among others, management systems, risk management, independent third-party auditing, and disclosure. For further detail, see our client briefing.

The Regulation encourages compliance with international guidelines for responsible procurement of these minerals and metals both within and outside the EU. In fact, the Regulation builds on other initiatives involving the EU, in particular the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. 

In the same vein, the Regulation also allowed governments, industry associations and organisations with due diligence schemes to apply for formal recognition by the Commission. Through Implementing Decision (EU) 2025/2071, the Commission recognised the equivalence of the RMAP under Article 8(3) of the Regulation. 

The recognised regime: RMAP

The RMAP, formerly known as the Conflict Free Smelter Program (CFSP), is RMI’s assurance programme designed to create transparent and responsible 3TG mineral supply chains. Its primary goal is to ensure that the sourcing and trade of tin and tantalum, tungsten and gold do not contribute to conflict, serious human rights abuses, money laundering, or insecurity. 

The RMAP standards provide an OECD-aligned, five-step audit framework, focused on smelters and refiners (entities processing raw ore into generic metal forms such as powders, products, or compounds). The RMAP standard does not apply to downstream economic operators, such as importers of metals into the EU.

These standards were last revised in 2017 and have been applied to all RMAP audits since 2019. The RMI submitted these standards for Commission recognition on 21 June 2019. 

Key features include:

• Five-step due diligence framework: Focuses on strong management systems, supply-chain risk identification and assessment, risk management, independent third-party audit of due diligence and public reporting.

• Risk-based, CAHRA focus: Smelters and refiners must identify, regularly review, and document areas affected by conflict or high risk, using “red flag” indicators such as locations of mineral origin or transit, unexplained production volumes, or failure to provide information. The RMI refers to the list of conflict-affected and high-risk areas under the EU Conflict Minerals Regulation and other relevant legislation, rather than providing its own.

• Facility-level conformance: Assessment and conformance are conducted at the level of each smelting or refining facility. 

• Annual review: Auditors review management systems annually to ensure robust, risk-based due diligence across the supply chain.

• Chain of custody and origin controls: Controls differ by material type (primary, recycled, legacy or assay). Non-conformant sources are subject to stricter requirements, while recycled or legacy materials may require less documentation within certain limits.

• Transparency: The RMAP promotes transparency through annual public due diligence reports, publication of conformant facility lists, and disclosure of policies and audit findings.

• Risk mitigation: Where risks are identified, auditees must implement mitigation plans, engage stakeholders, monitor progress, and suspend or terminate supply from problematic sources unless measurable improvement is achieved.

What it means for businesses

This recognition has a range of concrete implications for importers of minerals in the 3TG supply chain into the EU:

• Importers of minerals can now rely on the RMAP scheme to demonstrate compliance with their corresponding obligations under the Regulation – especially those relating to the management system, risk management, third-party audit, and disclosure obligations set out in Articles 4 to 7 of the Regulation.

• Importers of metals sourced from RMAP-conformant smelters and refiners are not themselves implementing the RMAP scheme and, therefore, cannot rely exclusively on it. While recognition does not lift their individual responsibilities, access to full audit reports can assist importers in meeting certain requirements (such as providing traceability and audit documentation). If such reports are unavailable, importers remain responsible for conducting full supply chain due diligence.

Looking ahead

The Commission has indicated that additional scheme recognitions may follow (see the state of play). It will also maintain a public register of recognised due diligence schemes, periodically review their effectiveness, and withdraw recognition where necessary. The Commission further intends to create an “EU Whitelist” of responsible global smelters and refiners, using data from recognised schemes and member state reports.

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