The European Commission’s Directorate‑General for Trade is preparing a voluntary platform to help downstream companies share due diligence information.
Procurement teams face growing pressure to prove clean supply chains for minerals that underpin electronics, batteries and renewables.
Yet transparency remains thin. In ICT, only 27% of companies disclose any portion of tier one supplier lists and just 9% publish complete named lists.
Despite widespread conflict minerals filings, many 2023 disclosures still could not determine the countries of origin for tin, tantalum, tungsten and gold. Beyond 3TG, disclosure is uneven. Some leaders, notably Apple, publish cobalt and lithium smelter and refiner lists, but this practice is far from universal.
With cobalt and lithium critical to electric vehicles and battery production, limited visibility hinders management of ethical, environmental or geopolitical risks. International agencies also flag supply concentration and policy risks across critical minerals, reinforcing the need for better disclosure and risk control.
The European Commission’s Directorate‑General for Trade is preparing a voluntary platform to help downstream companies share due diligence information. It is designed to complement, not replace, legal duties under the EU Conflict Minerals Regulation.
The platform will give miners, traders, manufacturers and retailers a space to describe how they track materials, the risk tools they use and how they work with suppliers. Public visibility would let civil society, regulators and customers see who takes responsible sourcing seriously.
For procurement, it offers a practical way to surface practices, benchmark against peers and evidence progress to stakeholders. It also creates a common venue to align on data expectations like named smelters and refiners, audit participation and incident response.
Standards procurement can lean on
The approach aligns with established frameworks. Teams can draw on the OECD Due Diligence Guidance, use industry templates such as the Conflict Minerals Reporting Template and the Extended Minerals Reporting Template and participate in recognised assurance programmes like the Responsible Minerals Assurance Process.
Embedding these into contracts, RFPs and supplier onboarding creates common language and comparable data which reduces duplicate questionnaires and accelerates risk triage.
Leaders show the art of the possible
Some companies already pair standards with digital tools. Siemens Energy integrates responsible sourcing into procurement using CMRT and aligns with the OECD Guidance.
It participates in industry groups such as the Responsible Minerals Initiative and requires suppliers to report mineral origins and join remediation when risks arise. Siemens Gamesa’s collaboration with Circulor and Ørsted used blockchain based tracking for copper in wind turbines, creating an auditable record of sourcing and emissions.
Apple’s supplier responsibility reports detail mineral sources, third party audit participation and actions taken when suppliers fail to meet expectations.
Apple has also developed software to map supply chains and publicly removes non compliant suppliers. Volkswagen has piloted blockchain enabled traceability, joining networks that follow minerals from mine to factory.
“Digitalisation and networking play a key role for the production and supply chains of the future,” says Murat Aksel, former Member of the Board of Management for Volkswagen.
“On the one hand, constantly connected data chains from the supplier to the manufacturer enable the flows of material to be organised more efficiently, meaning supply bottlenecks can be identified early on.
“On the other hand, digitalisation helps us to strengthen processes for observing environmental protection and human rights standards and to make supply chains even more transparent on these sensitive points.”
Murat’s company publishes audit results and shares practices across industry forums to encourage wider adoption, alongside using templates similar to CMRT and EMRT to streamline supplier reporting.
What procurement should do next
- Map mineral exposures beyond 3TG to cobalt, lithium, copper and rare earths
- Align policy with OECD Guidance, CMRT and EMRT, then require supplier use
- Stand up a single data model that links declarations, audits and chain of custody
- Pilot digital traceability for high risk materials and plan for scale
- Build contractual levers for audit rights, data access and corrective action
- Prepare to disclose via the DG TRADE platform to turn compliance into advantage
By creating a space for open disclosure, the DG TRADE platform can narrow the gap between regulation and practice. Procurement teams that act now will be better placed to secure partners, comply with future rules and respond fast when questions arise.
https://procurementmag.com/news/eu-mineral-supply-chain-traceability