[Minerals]Conflict/Responsible Minerals Update: RBA Statement on China Ministry of Commerce Decision

23 Aug 2026


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Greetings from MDSKorea.


On August 14, 2026, the RBA1) released an official statement regarding its inclusion on the sanctions list by China's Ministry of Commerce.

To help professionals easily grasp the situation, we have summarized the key points of the statement below.

1) An independent industry coalition dedicated to protecting workers' rights and the environment in global supply chains.



Overview (Background)

On August 5, 2026, China's Ministry of Commerce included six U.S. organizations, including the RBA, on its countermeasure list based on the Anti-Foreign Sanctions Law.

The primary reason is that these organizations supported U.S. sanctions related to Xinjiang. Inclusion on this list prohibits entities and individuals within China from engaging in transactions and other related activities with the listed organizations.

In response, the RBA stated that it takes this measure seriously and will strictly comply with regulations, while continuing to support its member companies' supply chain due diligence2). It also emphasized that it will maintain close communication to help members smoothly navigate these changes.

2) Investigative and management activities conducted by companies to identify and prevent risks within their supply chains.




Key Points

Q1. Will these Chinese sanctions have an immediate impact on our business operations?


There is no direct impact. This measure applies exclusively to companies and individuals operating within China. 

The RBA's global activities outside of China remain completely unaffected.


Q2. Then what happens to supply chains sourcing minerals from Chinese smelters?


Temporary measures will be applied to prevent supply chain disruptions. 

The RMI (Responsible Minerals Initiative), an initiative under the RBA, audits and certifies the mineral sourcing of smelters, and these certifications have an expiration date. Due to the current situation, the following measures will be applied to smelters and refiners in China:


  • Temporary Extension of Expiration Dates: The expiration date of the most recent audit will be extended until further notice.

  • Maintenance of the Roster: Consequently, even if the expiration date passes, the facility will not be removed from the RMI's3) public roster4) and will maintain its current status.

3) The responsible minerals management program operated by the RBA.

4) A public roster where the RMI discloses the certification status of smelters and refiners.


Q3. If the RBA is the one sanctioned, why are the expiration dates for Chinese facilities being extended?


Because the RMI, which conducts the smelter audits, is an initiative of the RBA, conducting on-site renewal audits in China has become practically impossible due to these sanctions.

If these delays cause normally operating Chinese smelters to be removed from the roster simply due to expiration, it would significantly disrupt the supply chains of global companies sourcing minerals from them. 

Therefore, the expiration dates have been temporarily extended to ensure that this unavoidable audit delay does not harm companies' supply chain management.




Conclusion (3-Line Summary)

  • The current Chinese sanctions are effective only within China and do not affect the RBA's global activities.

  • The RBA will continue its supply chain due diligence support as usual while complying with relevant regulations.

  • The certification expiration dates for Chinese smelters and refiners have been temporarily extended until further notice, keeping them on the active roster.


MDSKorea will always strive to provide you with useful and timely information. Thank you.


[Glossary]


TermDescription

RBA

Responsible Business Alliance. An independent industry coalition dedicated to protecting
workers' rights and the environment in global supply chains.
Supply Chain Due DiligenceInvestigative and management activities conducted by companies to identify and prevent risks within their supply chains.

RMI

Responsible Minerals Initiative.
The responsible minerals management program operated by the RBA.
RMI Public RosterA public roster where the RMI discloses the certification status of smelters and refiners.




[References & Links]



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