Sanctions and Compliance in Critical Mineral Trade
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Buyers of critical minerals face four overlapping rule sets. Sanctions block specific origins, such as the U.S. ban on Russian aluminum, copper and nickel produced on or after 13 April 2024. A U.S. forced labor law has presumed Xinjiang-linked goods barred since 21 June 2022. Conflict minerals rules require due diligence on tin, tantalum, tungsten and gold. And EU due diligence duties for batteries and large companies have been pushed back to 18 August 2027 and 26 July 2029.
13 Apr 2024
production cut-off date: Russian-origin aluminum, copper and nickel made on or after it cannot be imported into the U.S.
21 Jun 2022
date the U.S. presumption against goods made wholly or partly in Xinjiang took effect
18 Aug 2027
new start date for EU battery due diligence on cobalt, natural graphite, lithium and nickel (was 18 August 2025)
Source: Regulation (EU) 2025/1561
26 Jul 2029
new application date of the EU corporate due diligence directive, now limited to companies with over 5,000 employees and EUR 1.5 billion turnover
Source: Directive (EU) 2026/470
Which sanctions and due diligence rules apply to mineral trade?
The table sets out the main rules that bind buyers, with who each covers and the dates that matter. Rules that depend on a company's size or import volume should be checked against the legal text before use.
| Rule | Who it binds | What it requires | Date or status |
|---|---|---|---|
| U.S. ban on Russian aluminum, copper and nickel (Executive Order 14068) | Anyone importing into the U.S. | Importation and entry of aluminum, copper and nickel of Russian Federation origin is prohibited unless licensed. Metal produced before 13 April 2024 is excluded. | Determination signed 12 April 2024 by OFAC. |
| Uyghur Forced Labor Prevention Act | U.S. importers | Goods mined, produced or manufactured wholly or in part in Xinjiang, or by entities on the UFLPA Entity List, are presumed barred under 19 U.S.C. 1307. An importer must show by clear and convincing evidence that no forced labor was involved. | In effect from 21 June 2022. The Entity List includes aluminum, copper, silicon, lithium, magnesium, zinc and titanium producers. |
| Conflict minerals disclosure (15 U.S.C. 78m(p)) | Companies that file reports with the SEC and need conflict minerals | Report annually whether conflict minerals originated in the Democratic Republic of the Congo or an adjoining country; if so, give a due diligence report with an independent private sector audit. | In force. |
| EU Conflict Minerals Regulation 2017/821 | EU importers of tin, tantalum, tungsten and gold above volume thresholds | Supply chain due diligence on ores and metals, for example above 5,000 kg of tin ore, 250,000 kg of tungsten ore or 100 kg of unwrought gold a year. | Importer duties apply from 1 January 2021. |
| EU Batteries Regulation, Article 48 | Economic operators placing batteries on the EU market | Due diligence on sourcing, processing and trading of cobalt, natural graphite, lithium and nickel. | Application postponed from 18 August 2025 to 18 August 2027; Commission guidelines due 26 July 2026. |
| EU Corporate Sustainability Due Diligence Directive | Companies with over 5,000 employees and over EUR 1.5 billion turnover | Identify and address adverse human rights and environmental impacts in their chains of activities. | Application postponed to 26 July 2029; Commission guidelines by 26 July 2027. |
Sources: OFAC determination, CBP on the UFLPA, DHS Entity List, 15 U.S.C. 78m, Regulation (EU) 2017/821, Regulation (EU) 2025/1561 and Directive (EU) 2026/470.
What does the Russian metals ban cover?
The ban covers aluminum, copper and nickel of Russian origin. OFAC's determination under Executive Order 14068 prohibits importing them into the United States, including into a foreign trade zone, unless licensed, and it excludes metal produced before 13 April 2024. The cut-off is the production date, not the import date, so buyers need production records for Russian-origin metal. OFAC issued the determination in coordination with the United Kingdom, according to its published FAQ, and this page does not cover the UK or exchange rules in detail.
How does the forced labor law reach mineral supply chains?
The presumption applies to any good made wholly or partly in the Xinjiang Uyghur Autonomous Region or by an entity on the UFLPA Entity List. The DHS list includes entities whose names point to aluminum, copper, silicon, lithium, magnesium, zinc and titanium production, so metals buyers need to trace material back through smelters and processors. To obtain release of a detained shipment, the importer must overcome the presumption by clear and convincing evidence and answer CBP's information requests fully.
What changed for EU due diligence in 2025 and 2026?
Two EU deadlines moved later. Regulation (EU) 2025/1561 postponed battery due diligence to 18 August 2027, giving as reasons that notified bodies were taking longer to designate and that recognised due diligence schemes were not yet ready. Directive (EU) 2026/470 raised the corporate due diligence thresholds from 1,000 employees and EUR 450 million of turnover to over 5,000 employees and EUR 1.5 billion, and postponed application to 26 July 2029. The conflict minerals regulation was not changed by either text.
Frequently asked questions
Are Russian metals banned in the United States?
Russian-origin aluminum, copper and nickel produced on or after 13 April 2024 may not be imported into the United States unless OFAC licenses it. Metal produced before that date is excluded, so the cut-off is the production date.
What is the Uyghur Forced Labor Prevention Act?
The Uyghur Forced Labor Prevention Act creates a rebuttable presumption that goods made wholly or partly in Xinjiang, or by entities on the UFLPA Entity List, are made with forced labor and barred from U.S. import. It took effect on 21 June 2022, and importers must rebut it by clear and convincing evidence.
Which minerals are covered by conflict minerals rules?
The EU Conflict Minerals Regulation covers tin, tantalum, tungsten and gold, in ores and as metals, above set annual import volumes. The U.S. disclosure rule covers conflict minerals that may originate in the Democratic Republic of the Congo or an adjoining country.
When do the EU due diligence rules for batteries start?
EU battery due diligence on cobalt, natural graphite, lithium and nickel now applies from 18 August 2027. Regulation (EU) 2025/1561 moved it from 18 August 2025 because the bodies that verify compliance were not yet designated.
Sources
Read on October 12, 2026. Figures on this page come from these documents; where a number is an estimate, the source says so.
- OFAC: Determination under Executive Order 14068, aluminum, copper and nickel of Russian Federation origin (12 April 2024)
- U.S. Customs and Border Protection: Uyghur Forced Labor Prevention Act
- U.S. Department of Homeland Security: UFLPA Entity List
- 15 U.S.C. 78m (conflict minerals disclosure, subsection p)
- Regulation (EU) 2017/821, Article 1 and Annex I. Read on EUR-Lex
- Regulation (EU) 2025/1561 (postponing battery due diligence). Read on EUR-Lex
- Directive (EU) 2026/470 (Omnibus I amendments to the corporate due diligence directive). Read on EUR-Lex
