EU member states seem to be adopting a loose interpretation of the text of the Regulation on the responsible sourcing of minerals from conflict-affected and high-risk areas and seem unwilling to publish the list of national companies that fall under the Regulation. This also accounts for the Netherlands. Without this transparency, civil society groups both in Europe and in producing countries will not be able to monitor corporate behavior and to raise ‘substantiated concerns’, as provided in the law.

At this crucial point civil society organizations in Europe are calling on their governments to make sure that their respective implementation measures include provisions for the publication of the list of national importers subject to the Regulation.