Maturity Regulation (EU) 2017/821 · Due diligence on conflict minerals
Your 3TG supply chain, measured requirement by requirement and turned into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Maturity Regulation (EU) 2017/821 · Due diligence on conflict minerals
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2017/821 of 17 May 2017, applicable since 1 January 2021 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism, one level, the level above, and the action linking them, is what turns a finding into a trajectory.
Are the smelters and refiners upstream of your 3TG supply chain identified and assessed?
- N1
No identification beyond the direct supplier. Upstream smelters and refiners are unknown.
- N2
A partial list exists, built from declarations received. It is neither verified nor updated on a fixed schedule.
- N3
The list covers most flows, is updated at each annual cycle and checked against published lists of audited facilities.
- N4
Each smelter is linked to its flows, audit status and country of origin. Uncovered facilities trigger a documented risk assessment.
- N5
Identification is reviewed continuously in line with alerts and sourcing changes, with a history of decisions taken on each facility.
Action to move from L2 to L3
Set a fixed annual date for collecting supplier declarations, ahead of publishing the due diligence report, then check the resulting list against published lists of audited facilities and log the gaps in the risk management plan.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2017/821 sets the due diligence obligations for Union importers of four minerals and their metals: tin, tantalum, tungsten and gold, known by the acronym 3TG. It has applied since 1 January 2021 to importers exceeding the annual volume thresholds set out in Annex I. The text follows the structure of the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: management systems, risk identification and management, independent third-party audit of smelters and refiners, and annual public reporting.
In practice, the difficulty lies not in the text but in the depth of the chain. The importer buys a refined metal, sometimes several tiers away from the mine. Can you name every smelter or refiner upstream of your flows, not just your direct suppliers? What happens when a supplier refuses to disclose origin, or provides an unverifiable statement? Are your decisions on mitigation, suspension or disengagement traceable and validated by a named body, or handled case by case within procurement?
One piece of context has shifted the scope of the subject. Regulation (EU) 2024/1252 on critical raw materials and Regulation (EU) 2023/1542 on batteries extend the due diligence logic to other substances and other tiers of the chain, while the Corporate Sustainability Due Diligence Directive places the approach within a broader framework. A recurring point of confusion: membership of a sector scheme validating smelters does not exempt the importer from its own due diligence. It is a source of information, not proof of compliance.
A compliance audit settles the matter: the management system either exists or it does not, the annual report is either published or it is not. The maturity assessment asks a different question. At what level of control does each practice sit, from chain traceability to whistleblowing management, and what specific action moves it up a level. This is the reading that lets you sequence a transformation programme across several financial years and defend it before the national competent authorities.
In Datamensio, the framework is ready to use and adaptable. AI adjusts the themes, questions and levels to your position in the chain, importer, downstream processor or user, or builds a version from your sourcing policy and existing reports.
Reference standard: Regulation (EU) 2017/821 of 17 May 2017, applicable since 1 January 2021
The themes assessed
Scope and applicability
Identification of tin, tantalum, tungsten and gold flows, crossing the Annex I volume thresholds, distinction between minerals and metals, treatment of recycled materials and pre-existing stocks.
Management system and governance
Sourcing policy aligned with Annex II of the OECD Guidance, allocation of responsibility at management level, dedicated resources, integration into supplier contracts.
Traceability and chain of custody
Transaction records, identification of smelters and refiners, countries of origin and transit, transport routes, record-keeping and retention.
Risk identification and assessment
Criteria for qualifying conflict-affected or high-risk areas, information sources used, smelter-level assessment, upstream risk mapping.
Risk management and mitigation
Risk management plan, decisions to continue, apply measurable mitigation, suspend or terminate, escalation to management, tracking of measures over time.
Supplier engagement
Contractual clauses, questionnaires and declaration templates, evaluation of responses, support for underperforming suppliers, participation in sector schemes.
Independent third-party audit
Use of smelter and refiner audits, scope and independence of the verifier, use of findings, recognition of equivalent schemes.
Whistleblowing and grievance mechanisms
Channels open to workers and communities, handling of allegations of serious abuses, protection of whistleblowers, traceability of follow-up action.
Public communication and reporting
Annual due diligence report, content and accessibility, consistency with other sustainability disclosures, responses to downstream customer requests.
Relations with authorities and continuous improvement
Preparation for ex post checks by the national competent authority, record retention, periodic review of the framework, comparison of results year on year.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Can Regulation (EU) 2017/821 be certified?
No. It is a directly applicable regulation, checked ex post by the competent authorities designated by each member state. The assessment measures the maturity of your due diligence framework and prepares you for these checks, it does not issue any certificate.
What is the difference between this assessment and a compliance audit?
An audit concludes with a gap or a pass on each obligation. The assessment places each practice on a maturity scale and points to the action that moves it up a level. The two complement each other: the assessment sequences the programme, the audit validates it.
Our company sits downstream in the chain, are we affected?
The obligations fall on Union importers exceeding the Annex I thresholds. Downstream players are affected indirectly, through customer requests and related sustainability obligations. The framework adapts to this position in the chain.
How long does the assessment take?
The short version takes 20 to 30 minutes, completed by a procurement or compliance manager. The full version, run collaboratively, typically spans one to two weeks: most of the time goes into gathering transaction records and supplier declarations.
Can the framework be adapted to our flows?
Yes. You can amend the questions, levels and themes, distinguish between tin, tantalum, tungsten and gold, or start from your own sourcing policy. AI drafts the content and refines the levels, control of the framework remains yours.
How do we compare several business units or several cycles?
The same framework can be rolled out to each entity, with a score by theme and a target for each entity. The benchmark compares business units against each other and each against its own history, and a cross-cutting roadmap consolidates the action plans.
Does this assessment also serve the Critical Raw Materials Regulation or the Batteries Regulation?
These texts rest on converging due diligence principles, drawn from the same OECD guidance. The findings from the 3TG assessment form a reusable base, and the cross-cutting roadmap lets you cross-reference several frameworks without duplicating actions.
Where is the data hosted?
In France, with OVH, backed up at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.