Supply Chain & Due Diligence

3TG minerals (tin, tantalum, tungsten, gold)

Collective term for tin, tantalum, tungsten and gold — four minerals whose extraction and trade have been linked to financing armed conflict, and which are covered by dedicated due diligence legislation.

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Definition

Shorthand for the four minerals and metals defined in Section 1502 of the US Dodd-Frank Act (2010) as columbite-tantalite (tantalum ore), cassiterite (tin ore), wolframite (tungsten ore) and gold. The same four are covered by the EU Conflict Minerals Regulation, whose importer obligations have applied since 1 January 2021.

References

OECD

Five-step risk-based due diligence framework; model supply chain policy; status as de facto international standard.

Merck (MSD)

Dodd-Frank §1502 definition of the four ores/metals; SEC conflict minerals reporting rule mechanics.

Overview

What it means

3TG are embedded in electronics, automotive, aerospace, medical and other manufactured products. In the Democratic Republic of the Congo and adjoining countries — and, under the EU framework, any conflict-affected or high-risk area (CAHRA) — their extraction has historically financed armed groups and been linked to severe human rights abuses.

How it is used

US-listed companies determine whether 3TG necessary to their products originated in covered countries and report to the SEC. EU importers above set thresholds must apply the OECD five-step due diligence framework, including third-party audits of smelters and refiners. Industry reporting templates (such as the CMRT) are used to trace smelters and countries of origin.

Why it matters

3TG rules were designed to break the link between mineral trade and conflict financing. They made mineral supply chain due diligence a mainstream compliance function. Debate continues over effectiveness, reporting burdens and unintended impacts on legitimate mining livelihoods in affected regions.

Definitions and controversy

US law ties the term to the DRC and adjoining countries; the EU applies it globally to CAHRAs. "Conflict minerals" in general usage can extend beyond these four, so the terms are related but not always interchangeable.

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