Answer · confidence: partial

How do big phone and battery companies check their cobalt isn't from illegal mines?

Research question: How do global electronics and battery manufacturers trace the origin of their cobalt to ensure it is not sourced from illegal artisanal mines?

Chain of custody standards aim to ensure minerals come from credible sources and are accompanied by verifiable information ¹. The Responsible Minerals Initiative offers a Cobalt Reporting Template that companies can use to map their cobalt supply chain ¹⁰, and its Responsible Minerals Assurance Process includes standards and assessment documents ¹². The RMI links upstream and downstream companies and promotes accountability through third-party assessments and facility data ¹⁴, but it states that it does not itself validate minerals, materials, or mines, which limits what its programs can confirm about a mine's origin ¹⁶. The stakes are significant because many DRC artisanal cobalt mines are reportedly illegal, unsafe, polluting, and employ children ¹¹, and artisanal miners supply an estimated 20 to 40% of DRC cobalt, according to Trafigura ¹³. The newest verified fact is dated 2 October 2026, only days before today's date, but the facts do not describe how battery makers specifically screen cobalt for artisanal origin, and the U.S. rules on FEOC tracking ³⁵⁶ and DFARS due diligence ⁷ cover different purposes and minerals.

Checked 2026-10-23. Only documented and supported facts are used.

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Sources

[1] supported

Chain of Custody standards ensure that minerals are from credible sources and accompanied by verifiable information.

"It ensures that the minerals they have received are from credible sources and accompanied by verifiable information."

Beyond Traceability: Leveraging Opportunities and Innovation in Chain of Custody Standards for the Mining Industry (2025)

[2] documented

Manufacturers can allocate FEOC-compliant critical minerals and constituent materials to battery cells without physical tracking, provided they follow specific regulatory paragraphs.

"FEOC-compliant applicable critical minerals and associated constituent materials (but not battery components) may be allocated to battery cells, without physical tracking, in accordance with paragraph (c)(3)(ii) of this section."

Clean Vehicle Credits Under Sections 25E and 30D; Transfer of Credits; Critical Minerals and Battery Components; Foreign Entities of Concern (Treasury Department, Internal Revenue Service, 2024-05-06)

[3] documented

The determination of whether a battery cell is FEOC-compliant can be made by applying a transition rule for materials that are impracticable to trace.

"In addition, the determination of whether a battery cell is FEOC-compliant may be made by applying the transition rule for impracticable-to-trace battery materials, in accordance with paragraph (c)(3)(iii) of this section."

[4] documented

Battery components, including cells, must be physically tracked to specific clean vehicle batteries to ensure compliance.

"The battery components, including battery cells, are physically tracked to specific clean vehicle batteries, in accordance with paragraph (c)(2) of this section."

[5] documented

A serial number or other identification system is required to physically track FEOC-compliant battery cells to specific batteries.

"With respect to battery cells, a serial number or other identification system must be used to physically track FEOC-compliant battery cells to such batteries."

[6] documented

The determination that a battery cell contains FEOC-compliant materials requires physically tracking the mass of FEOC-compliant applicable critical minerals and their associated constituent materials.

"the determination that a battery cell contains FEOC-compliant battery components and FEOC-compliant applicable critical minerals and their associated constituent materials must be made by physically tracking FEOC-compliant battery components to specific battery cells, and by physically tracking the mass of FEOC-compliant applicable critical minerals and the"

[7] documented

Publicly-traded U.S. companies are required to conduct supply chain due diligence on minerals like tantalum and tungsten to ensure they do not support armed conflict in the Democratic Republic of Congo and adjoining countries.

"For those materials not currently covered by DoD investments, such as tantalum and tungsten, publicly-traded U.S. companies, including DoD contractors and their subcontractors, already are required to conduct supply chain due diligence on these minerals when they are necessary to the functionality or production of a product manufactured by that company. This requirement stems from section 1502 of "

Defense Federal Acquisition Regulation Supplement: Restriction on Certain Metal Products (DFARS Case 2021-D015) (Defense Department, Defense Acquisition Regulations System, 2024-05-30)

[8] documented

Effective January 1, 2027, the restriction on samarium-cobalt magnets will include the entire supply chain from mining or production of cobalt and samarium ore or feedstock through the production of finished magnets.

"Effective January 1, 2027, for samarium-cobalt magnets this restriction includes the entire supply chain from mining or production of a cobalt and samarium ore or feedstock, including recycled material, through production of finished magnets, except as provided at 225.7018-3."

Defense Federal Acquisition Regulation Supplement: Restriction on Certain Metal Products (DFARS Case 2021-D015) (Defense Department, Defense Acquisition Regulations System, 2024-05-30)

[9] documented

The restriction on the acquisition of certain magnets, tantalum, and tungsten is designed to provide industry a six-year phase-in period to develop alternative sources of supply from countries other than China, Russia, North Korea, and Iran.

"This five-year phase-in period, now revised to six years by section 854 of the NDAA for FY 2024, provides a reasonable period for industry to develop alternative sources of supply for covered materials from sources other than the People's Republic of China, the Russian Federation, the Democratic People's Republic of North Korea, and the Islamic Republic of Iran."

Defense Federal Acquisition Regulation Supplement: Restriction on Certain Metal Products (DFARS Case 2021-D015) (Defense Department, Defense Acquisition Regulations System, 2024-05-30)

[10] supported

The Responsible Minerals Initiative offers a Cobalt Reporting Template (CRT) that companies can use to map their supply chain for cobalt.

"Download our Conflict Minerals Reporting Template (CMRT) or Cobalt Reporting Template (CRT) to map your supply chain."

What changed on www.responsiblemineralsinitiative.org/ between 2017-10-21 and 2026-10-02

[11] supported

Many artisanal cobalt mines in the DRC are reportedly illegal, unsafe, polluting, and employ children.

"Beaucoup de mines artisanales seraient illégales, peu sûres, polluantes et feraient travailler des enfants"

Économie de la république démocratique du Congo

[12] supported

The RMI's flagship program for verifying responsible mineral sourcing is the Responsible Minerals Assurance Process (RMAP), which includes standards and assessment documents.

"Learn about our flagship Responsible Minerals Assurance Process (RMAP) and access the standards and assessment documents."

What changed on www.responsiblemineralsinitiative.org/ between 2017-10-21 and 2026-10-02

[13] supported

According to Trafigura, artisanal miners ('creuseurs') supply an estimated 20 to 40% of the cobalt produced in the DRC.

"Selon la société Trafigura , ces « creuseurs » fourniraient de 20 à 40 % du cobalt produit en RDC."

Économie de la république démocratique du Congo

[14] supported

The RMI links upstream and downstream companies and promotes accountability through third-party assessments and facility data.

"The RMI serves as a bridge between upstream and downstream companies , facilitating accountability and transparency through third-party assessments, facility data, and reporting on minerals due diligence."

What changed on www.responsiblemineralsinitiative.org/ between 2017-10-21 and 2026-10-02

[15] supported

The DRC produces more than half of the world's cobalt, about 90,000 tonnes a year.

"Avec une production annuelle d'environ 90 000 tonnes (2019), la RDC représente plus de la moitié de la production mondiale de cobalt"

Économie de la république démocratique du Congo

[16] supported

The RMI states that it does not itself validate minerals, materials, or mines, which limits what its programs can confirm about a mine's origin.

"The RMI does not validate minerals, material or mines."

What changed on www.responsiblemineralsinitiative.org/ between 2017-10-21 and 2026-10-02