Responsible sourcing and due diligence

"Responsible sourcing" is one of the most over-claimed phrases in commodity marketing. Every supplier brochure says it. Few documentation packs back it up. For a buyer whose downstream customer is subject to CMRT (Conflict Minerals Reporting Template), RMI (Responsible Minerals Initiative) audit, or the EU Deforestation Regulation, the gap between claim and evidence is where contracts unravel.

What an OECD-aligned pack actually contains

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas is not a one-page certificate. It is a five-step framework: establish strong management systems, identify and assess risk, design and implement a response strategy, support third-party audits, and report publicly. For a trader, alignment means producing evidence at each step.

1. Mine-side documentation. Mine concession certificate from the producing country’s mining authority. Export permit covering the specific parcel and tonnage. Production records linking the parcel to a specific mine site, not "Zimbabwe origin" in the abstract.

2. Chain-of-custody. Every transfer between mine, concentrator, warehouse, port, and vessel logged with bill of lading, weighbridge tickets, and inspection sign-offs. The goal is that any auditor can reconstruct the parcel’s path from pit to port without gaps.

3. CMRT statement. Where requested, a Conflict Minerals Reporting Template completed at the parcel level, identifying smelters/refiners downstream where applicable and confirming no sourcing from sanctioned or armed-group-controlled mine sites.

4. Sanctions screening. Every counterparty in the chain screened against OFAC, EU consolidated, UK HMT, and UN lists at the date of shipment, with screening logs retained.

What it does not contain

It does not contain self-issued certificates with logos that look official. It does not contain "based on supplier assurance" language that pushes responsibility one step back without verification. It does not contain marketing brochures dressed up as compliance documents.

Why this matters commercially

EU buyers preparing for full EUDR enforcement, US buyers facing IRA critical-minerals provenance requirements, and Japanese aerospace primes running RMI audits will not accept incomplete packs from 2026 onward. A trader who cannot produce the documentation at parcel level — not at company level, not at "we usually do this" level — loses the contract.

Richfull Trading produces this pack for every shipment by default, not on request. The cost of building it once and replicating it is materially lower than the cost of losing an offtake midway through a compliance audit.