What is cobalt?
Cobalt is a heavy metal that was initially used mainly to colour glass and ceramics. It has been used in batteries since the 1990s in particular, and is now found in all mobile phones, smartphones and electric cars. Although alternatives are now available (various companies are working on batteries that are largely cobalt-free), demand remains high.
Cobalt is mostly mined in the Democratic Republic of Congo, where more than 50 percent of the world's known cobalt deposits are located. As with the other conflict minerals (tin, tantalum, tungsten, gold; also known as 3TG in their entirety), mining here often takes place under problematic conditions. As early as 2017, a report by Amnesty International on child labour in the supply chain drew attention to the issue, further reports followed for example on raconteur.net and washingtonpost.com, among others.
What are the regulations?
Originally, cobalt was to be the fifth conflict mineral, besides the 3TGs mentioned above, whose use was to be regulated by the Dodd-Frank Act (Sec. 1502). However, this failed due to the resistance of numerous companies. After all, the careful examination of the origin is very costly. Since cobalt was initially processed primarily as a by-product of copper and nickel mining, the smelters could not be easily identified and validated. While the Excel-based CMRT for 3TG's reporting follows the IPC-1755 standard, there are currently no legal requirements for the cobalt supply chain.
Nevertheless, a Cobalt Reporting Template (CRT), provided by the Responsible Minerals Initiative, has been in place since 2018. Version CRT 2.0 was released in October 2019 and the next revision is planned for autumn 2020. A reference list of the smelters can be downloaded here.
Background of the CRT are the OECD guidelines on due diligence. The aim is to collect information on the origin of the minerals and the smelting and refining facilities. Many companies, such as Apple, have now voluntarily committed themselves to tracking and disclosing the entire cobalt supply chain. According to the OECD guidelines, unlike the Dodd-Frank Act for the 3TG, reporting refers to all conflict and high risk areas (CAHRAs).
Cobalt (CAS No. 7440-48-4) is also covered by REACH because it can have long-term adverse effects on aquatic life, cause an allergic skin reaction and, if inhaled, may cause allergy or asthma symptoms or breathing difficulties. Therefore, manufacturers and importers must provide guidance on the safe use of the substance and take precautionary measures.
What can we do for you?
We can advise you on all questions regarding the documentation of cobalt and support you in optimising your internal processes and answering your customers' enquiries in due time. We help you to fill in the CRT correctly. Just contact us.