[Minerals]Conflict/Responsible Minerals Update: EU Commission officially recognizes RMAP as a due diligence scheme for Conflict Minerals Regulation compliance

2 Nov 2025

On October 20, 2025, the Responsible Minerals Initiative (RMI) announced that its Responsible Minerals Assurance Process (RMAP) has become the first supply chain due diligence scheme officially recognized by the European Commission for EU importers’ compliance with the Conflict Minerals Regulation (CMR). 

※ RMI: Responsible Minerals Initiative
※ RMAP: Responsible Minerals Assurance Process
※ CMR: Conflict Minerals Regulation

 


Meaning of Official Recognition of RMAP

This designation signifies that the European Union has acknowledged the RMAP as a credible and officially recognized system that meets the due diligence requirements under the EU CMR.
Accordingly, EU importers can effectively fulfill their CMR obligations by utilizing the RMAP framework.


Scope of EU CMR and RMAP Recognition

The EU CMR (Regulation (EU) 2017/821) aims to ensure that EU importers, smelters, and refiners sourcing minerals from conflict-affected and high-risk areas manage their supply chains in a transparent and responsible manner. This regulation is built upon the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, adopting a risk-based due diligence approach.

The European Commission has determined that the RMI’s RMAP standards and implementation fully comply with the requirements of both the EU CMR and the OECD Guidance. While EU importers retain ultimate responsibility for compliance with the CMR due diligence obligations, they can effectively meet the regulation’s requirements—covering management systems, risk management, third-party audits, and disclosure—by utilizing recognized supply chain due diligence schemes such as RMAP. The scope of this recognition includes the following standards. It does not apply to other schemes cross-recognized by RMI, but only to smelters and refiners that have been assessed as conformant under the RMAP program and standards themselves.

  • RMAP Tin and Tantalum Standard

  • RMAP Tungsten Standard

  • RMAP Gold Standard


Future Actions and Recommendations in the EU

The European Commission plans to create a List of global responsible smelters and refiners, based on information from recognized supply chain due diligence schemes and annual implementation reports submitted by EU Member States. Therefore, EU importers are encouraged to promptly provide evidence of conformity with the RMI’s RMAP to their respective Member State Competent Authorities.


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