PUBLIC CONSULTATION ON A POSSIBLE EU INITIATIVE ON RESPONSIBLE SOURCING OF MINERALS ORIGINATING FROM CONFLICT-AFFECTED AND HIGH RISK AREAS. The EU Commission is running a public consultation on so-called “conflict minerals”.   The Commission will use the results to help it decide whether or not to introduce legislation in relation to the responsible sourcing of minerals from for example war zones, post-war zones, and areas vulnerable to political instability or civil unrest. The consultation closes on 26^th June 2013. This is an important and significant issue for the fine and fashion jewellery industry, watches and fashion accessories. Does the UK jewellery industry want an EU legislative regulation (a law) that might be a sort of version of the United States’ ‘Dodd Frank Act’ (that covers gold, tin, tungsten and tantalum originating from the DRC or an adjoining country)? NB: The EU consultation does not specify which geographical areas or which particular minerals might be included. It could conceivably include diamonds and gemstones Alternatively would the trade prefer to adopt the ‘UN Guiding Principles on Business and Human Rights’ and have a voluntary code more along the lines of the ‘OECD Due Diligence Guidance’ or the ‘Extractive Industry Transparency Initiative’? On one hand the collapse of the clothing factory building in Bangladesh suggests that voluntary codes of practice in relation to due diligence through the supply chain don’t work. On the other hand the Dodd Frank Act in the USA has triggered the law of unintended consequences, such that it has become so bureaucratic and onerous for legitimate suppliers to obtain gold, tin, tungsten and tantalum from the DRC and surrounding countries that they have abandoned sourcing from that area altogether, leading to a collapse in legitimate trade. This has inevitably been replaced by criminal activity and illegitimate trade to the detriment of the artisanal mining community and the countries as a whole. Whether there is a law or voluntary code, we must make sure we choose our words carefully to ensure that gold does not get labelled generally as a “conflict mineral” instead of as “a legitimately sourced mineral from a conflict-affected area” which it may sometimes be. Please make sure you have your say by answering the questionnaire by 26^th June 2013. Click here to view the consultation document   http://trade.ec.europa.eu/consultations/index.cfm?consul_id=174 Michael Allchin Chief Executive and Assay Master The Birmingham Assay Office  

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