The Japan Business Council in Europe (JBCE) and the Japan Electronics and Information Technology Industries Association (JEITA) have released a joint position paper on the European Union’s (EU) integrated approach on responsible sourcing of minerals originating from conflict-affected and high-risk areas. The JBCE and JEITA strongly support to the EU in its efforts to establish a market for responsibly traded minerals that originate in conflict regions while also welcoming the objective of reducing market distortions in minerals sectors from DRC and the Great Lakes Region. More specifically, the joint paper provides comments to both the European Commission’s proposal for a regulation and the communication on “conflict minerals”.

In response to the proposed regulation, the JBCE and JEITA call for an exclusion of recycled or scrap materials from the scope, and for the development of clear guidance to identify “conflict-affected or a high-risk area” through a transparent process in collaboration with relevant stakeholders. While welcoming the Commission’s focus on importers in the proposed regulation, the two organisations stress the need for clear criteria when it comes to the certification of “responsible” importers. Finally, the joint paper advocates for the introduction of incentives focusing on upstream operations in order to effectively stimulate responsible sourcing from conflict-affected areas.

In response to the Commission’s Communication, the JBCE and JEITA notably call on the Commission to lay down guidelines on appropriate due diligence methods to encourage an effective information transfer throughout the supply chain. The two organisations wish to stress that industry alone cannot ensure responsible sourcing from conflicted-affected regions. Instead, the support of national governments, including those of the US and Japan, are crucial in achieving this objective.