Unlike the US conflict minerals law, the due diligence requirement does not only apply to minerals sourced from the DRC region. There will also be exemptions for recycled materials and small importers, accounting for 5% of imports. Although there will only be mandatory due diligence for importers of minerals, large companies using these in their products will be encouraged to also disclose their sourcing practices and will be able to join an EU registry.
The next step in the legislative process will be for the Council to approve the draft regulation; it will then be published in the EU Official Journal. Due diligence obligations will apply from 1 January 2021 to allow sufficient preparation time for Member States and importers.