Editor’s Note
This article outlines new EU regulations requiring importers of key minerals to conduct supply chain due diligence, aiming to improve working conditions at extraction sites.

Since January 1, 2021, importers of certain critical metals widely used in digital technology must comply with “obligations related to supply chain due diligence from conflict-affected or high-risk areas.” Indeed, all European Union member states must have transposed Regulation (EU) 2017/821 of May 17, 2017, into national law.
The objective of the regulation coming into force is to regulate the extraction of four minerals – tin, tantalum, tungsten, and gold – among the 10 main ones necessary for manufacturing smartphones, computers, etc.
Completely unnoticed, the entry into force of this regulation is a major step forward. It is the culmination of the work of over 150 NGOs and opinion leaders across Europe for 10 years, including Amnesty International, ActionAid, CCFD-Terre Solidaire, Global Witness, GreenIT.fr via Good Electronics, Oxfam France, Sherpa, Walk Free. See the exhaustive list [2].
This text aims to put an end to “conflict minerals,” minerals so precious that they finance armed conflicts in unstable countries. The consequences include forced labor of adults and children, expropriation of indigenous peoples, rape, etc. After “blood diamonds” [3], coltan in the Democratic Republic of Congo has become the symbol of these “conflict minerals.”
Europe will thus catch up with the USA, which passed a similar type of legislation 10 years ago. The US Dodd-Frank Act [4], adopted in 2010, includes the obligation for US-listed companies sourcing minerals from the Great Lakes region to report on their supply chains.
While we can only welcome this progress, this text will only be a real improvement when it is implemented and when the due diligence is effectively controlled by third-party organizations on the ground, such as Electronics Watch and its partners. Without this, this regulation is useless.
Too many large private and public organizations, if not all, simply hide behind a few International Labour Organization (ILO) conventions, hoping their suppliers do what they say they do.
Child labor and inhumane working conditions unfortunately are not limited to extraction.
For over 16 years, along with other NGOs and associations [5], we have been denouncing working conditions in assembly factories.
According to China Labor Watch, during peak periods like before the end-of-year holidays, these same employees work 3 to 6 times more than the legal limit: up to 220 overtime hours per month, in addition to normal working hours, meaning up to 15 to 16 hours of work per day, with, at best, one day off per month.
In 2014, after the campaign led in the United States by NGOs Green America and China Labor Watch,
More recently, it was discovered that one had to
Finally, the other major ignored area is that of “recycling.” 70% of electronic waste subject to global trafficking ends up most of the time in slums – such as Agbogbloshie in Ghana – dedicated to recovering the precious metals they contain. In this slum, food produced locally contains