Conflict minerals due diligence for UK product companies

UK product companies must conduct conflict minerals due diligence to identify and mitigate risks linked to 3TG minerals originating from conflict-affected areas. This process helps ensure supply chains respect human rights and avoids contributing to armed conflict in regions such as the Democratic Republic of Congo.

Responsible sourcing demonstrates care to customers, partners and regulators while protecting your brand from reputational damage. The following guide provides practical, step-by-step actions that early-stage founders and e-commerce sellers can take to build effective due diligence systems.

Understanding 3TG minerals and their relevance

3TG refers to tin, tantalum, tungsten and gold. These minerals are widely used in electronics, jewellery, automotive parts, machinery and consumer goods. Many UK importers and manufacturers rely on components or finished products that contain them.

The concern arises when these minerals are mined in areas affected by armed conflict and human rights abuses. Revenue from their sale can fund armed groups. UK companies are expected to know whether their products contain 3TG and to understand the origin and processing of these materials. This expectation applies whether you import components, finished goods or work with overseas contract manufacturers.

Practical first step: list every product you sell or plan to sell. For each item, identify any metal or electronic component that could contain 3TG. Ask your existing or prospective suppliers for a bill of materials or material composition statement. This creates a starting point for further due diligence.

UK reporting obligations for conflict minerals

UK rules on conflict minerals continue to evolve and align in many respects with EU regulations. Companies may face obligations to disclose information about 3TG in their supply chains, particularly if they import certain volumes or operate in regulated sectors. Requirements can change, so always check the latest guidance on GOV.UK.

Even where formal reporting is not mandatory, many UK businesses adopt due diligence to meet customer expectations, platform policies or investor requirements. Large retailers and online marketplaces often ask suppliers for evidence of responsible sourcing before listing products. Demonstrating that you have assessed 3TG risks can therefore be a commercial necessity.

Begin by determining whether any of your products fall within categories likely to contain 3TG, such as electronics, batteries, jewellery or tools. Document your findings. If you discover potential exposure, record the steps taken to investigate further. This documentation forms the basis of any future reporting or audit response.

Creating a responsible sourcing policy

A written responsible sourcing policy sets out your company’s commitment to ethical supply chains. Keep the document concise, usually one or two pages, and make it publicly available on your website.

Core elements to include:

A clear statement that the company will not knowingly source 3TG that directly or indirectly finances armed conflict.
Commitment to conduct due diligence in line with recognised frameworks such as the OECD Due Diligence Guidance.
Expectation that all suppliers will provide information about the origin of 3TG materials.
Consequences for suppliers that refuse to cooperate or are found to source from high-risk areas without adequate controls.
Process for reviewing and updating the policy annually.

Share the policy with every new supplier during onboarding. Reference it in contracts or terms of purchase. This creates a consistent standard across your supply base and helps when responding to customer or platform enquiries.

Designing and using supplier questionnaires

Supplier questionnaires are the main practical tool for gathering information about 3TG. Send a standardised form to every supplier that provides components or products that may contain tin, tantalum, tungsten or gold.

Effective questions include:

Does any material or component in the supplied product contain 3TG?
If yes, please provide the names of all smelters or refiners in the supply chain.
Are any of the 3TG minerals sourced from the Democratic Republic of Congo or adjoining countries?
Have you conducted due diligence on your own suppliers in accordance with OECD or equivalent guidance?
Can you provide a completed Conflict Minerals Reporting Template (CMRT)?
Do you have a responsible sourcing policy and, if so, may we see a copy?

Request that responses are updated at least annually or when supply sources change. Follow up promptly on incomplete or unclear answers. For suppliers based overseas, particularly in Asia, be prepared to explain the purpose of the questionnaire and offer help completing it. Small suppliers may lack English-language documentation; consider providing a simplified version or arranging a call to walk through the questions.

Keep all completed questionnaires in a central folder linked to each product. This creates an audit trail that can be produced quickly if a customer, platform or regulator asks for evidence of due diligence.

Assessing and mitigating risks in practice

Once questionnaires are returned, review the information for red flags. These include suppliers that do not know their smelters, those that source from the covered countries without independent validation, or those that fail to respond after repeated requests.

Reasoning example: a UK e-commerce seller sourcing wireless earbuds from a Chinese factory receives a CMRT listing five smelters. Three are certified as conflict-free by recognised schemes. Two have unknown status. The seller then asks the factory to replace the two unknown smelters or provide further evidence within 60 days. If the factory cannot comply, the seller begins qualifying an alternative supplier. This demonstrates active risk management rather than simply collecting paperwork.

Practical mitigation steps include:

Prioritising suppliers that use smelters listed on the Responsible Minerals Initiative’s conformant list.
Building longer-term relationships with a smaller number of transparent suppliers instead of frequently switching for cost reasons.
Including due diligence clauses in purchase orders that require notification of any change in smelter or mine source.
Visiting factories or commissioning third-party audits when volumes justify the cost.

For very early-stage companies with limited budget, focus first on high-volume or high-margin products. Extend due diligence to lower-volume lines as the business grows.

Maintaining records and continuous improvement

Document every stage of the process. Records should include your product list, supplier responses, risk assessments, follow-up correspondence and any decisions to change suppliers. Retain these for at least five years or as required by your customers and platforms.

Review your due diligence system once per year. Update the responsible sourcing policy, refresh supplier questionnaires and check for new guidance on GOV.UK or from industry groups. As your product range expands, repeat the mapping exercise for new items.

When dealing with overseas suppliers, language and time-zone barriers can slow progress. Schedule regular calls, use clear templates and consider working with a sourcing agent who understands both UK expectations and local realities. This investment often pays for itself by preventing delays or reputational issues later.

Integrating due diligence into your operations

Embed conflict minerals checks into existing processes rather than treating them as a separate project. Add a due diligence status field to your product database. Make completion of the supplier questionnaire a prerequisite for approving a new supplier or placing the first order. Train anyone who works with suppliers to recognise 3TG risks and escalate incomplete information.

For e-commerce sellers using platforms that require ethical sourcing declarations, having a completed due diligence file allows quick responses to audit requests. This reduces the risk of listings being suspended.

Loomworks in West Yorkshire offers selected early-stage founders free desks, a registered address and mentoring that can help new product companies put practical systems like these in place without heavy upfront costs.

Frequently asked questions

What are 3TG conflict minerals?

3TG stands for tin, tantalum, tungsten and gold. These minerals are used in many electronic and consumer products. When sourced from conflict-affected regions, particularly parts of the Democratic Republic of Congo, their trade can contribute to armed violence and human rights abuses. UK companies are expected to investigate whether their supply chains include these materials and to take steps to avoid contributing to harm.

Do all UK companies have to report on conflict minerals?

Reporting obligations depend on the products you import, your company size and the sector. Requirements can change, so check current GOV.UK guidance. Even when not strictly required, many UK e-commerce sellers and product companies complete due diligence to satisfy customer expectations, online platform policies and investor requests.

How do I get suppliers to complete a conflict minerals questionnaire?

Send a clear, standardised form early in the relationship. Explain that the information is needed for UK compliance and to protect both parties’ reputations. Offer to walk through the questions on a call. Follow up politely but firmly. Persistent small suppliers may need simplified templates or translation help. Make the questionnaire a condition of doing business.

What should a responsible sourcing policy contain?

The policy should state your commitment not to source 3TG that funds conflict, reference recognised due diligence standards such as the OECD guidance, set expectations for suppliers, and describe your review process. Keep it short, publish it on your website and include it in supplier contracts. Review and update it each year.

Can small UK startups afford proper due diligence?

Yes. Start by mapping only your highest-volume or highest-risk products. Use free templates such as the Conflict Minerals Reporting Template. Focus effort on suppliers representing the majority of your spend. As the business grows, expand the programme. Many practical steps rely on clear communication and consistent processes rather than expensive consultants.