Can the EU Close Supply Chain Mineral Traceability Gaps?

The European Commission is moving to improve transparency in mineral sourcing, as the Directorate-General for Trade (DG TRADE) prepares a voluntary platform for downstream companies to share due diligence information. 

Transparency remains limited across supply chains. In the ICT sector, only 27% of companies disclose any portion of their tier-one supplier lists and just 9% publish complete named lists. 

For an industry under pressure to prove clean sourcing, that level of disclosure falls short.

Traceability gaps still run deep, despite widespread conflict-minerals filings, many 2023 disclosures still could not determine the countries of origin for tin, tantalum, tungsten and gold (3TG).

Beyond 3TG, disclosure remains uneven. Some companies, notably Apple, publish cobalt and lithium smelter and refiner lists, yet comparable transparency is not universal across the sector.

This matters because cobalt and lithium are critical to electric vehicles and battery production. Without broader due diligence, companies struggle to manage ethical, environmental or geopolitical risks tied to these materials. 

Meanwhile, international agencies warn of heightened supply-concentration and policy risks across critical minerals, underlining the need for better disclosure and risk management.

What the EU platform would do

DG TRADE’s planned platform is voluntary and designed to complement, not replace, legal duties under the EU Conflict Minerals Regulation.

It would give companies from miners and traders to manufacturers and retailers a place to describe how they track materials, the risk-management tools they use and how they work with suppliers. 

Public visibility would allow civil society, regulators and customers to see who is taking responsible sourcing seriously.

The approach aligns with established frameworks. Companies can draw on the OECD Due Diligence Guidance, use industry templates such as the Conflict Minerals Reporting Template (CMRT) and the Extended Minerals Reporting Template (EMRT), and participate in recognised assurance programmes like the Responsible Minerals Assurance Process (RMAP).

How major companies are setting an example

Some companies are already showing how digital tools and standards can raise the bar. 

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. 

Meanwhile, 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 also 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,” explained 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.”

The manufacturer 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.

Why transparency now? 

As scrutiny intensifies, companies willing to disclose how they manage mineral risks will be better placed to secure partners, comply with future rules and respond when questions arise. 

By creating a space for open disclosure, the forthcoming DG TRADE platform aims to close the gap between regulation and practice and turn transparency from a compliance necessity to a competitive advantage.