Understanding Traceability vs. Certification
A key weakness in a number of recent assessments of progress on certification of conflict minerals in the Great Lakes Region is confusion regarding the concepts of certification and traceability. Certification, in its most broad sense, is about creating the conditions for long-term reform of the governance of mineral sectors. Traceability, while critical, is one small part of this bigger picture. Traceability refers to the use of documented and recorded identification to follow commodities or goods as they move through the supply chain. Ongoing confusion regarding these two concepts has not been helpful, and has more often than not muddied analysis of the progress and impact of efforts in the region.
To better understand the scope of activities involved in certification it is helpful to explore in more detail the many components involved in implementation of the Regional Certification Mechanism of the International Conference on the Great Lakes Region (ICGLR). This mechanism is binding upon eleven ICGLR Member States and in many cases is mirrored through domestic legislation. It is also aligned with the voluntary OECD Due Diligence Guidance for Responsible Supply Chains of Minerals and, by extension, makes the voluntary OECD five-step framework legally binging as well, but on private sector actors in-region.
The ICGLR Regional Certification Mechanism requires that mine sites pass government inspections, that minerals be traceable from mine site to export, and includes requirements that exporters pass a third party audit once per year. Before export, the government must review and verity this information for each mineral shipment. Only then will compliant mineral shipments be awarded an ICGLR Certificate. The chain of custody data is to be published online, and the overall system is to be verified by the equivalent of a chain of custody Ombudsman - unfortunately named the Independent Mineral Chain Auditor (IMCA). In other words, the ICGLR RCM has long-term vision that includes improved natural resource governance within a framework of intraregional cooperation and peace.
Equally important is the centrality of transparency to these efforts. While many critics have drawn attention to the slow pace of progress in making certification a reality, few have noted the vital importance of transparency, through the publication of inspections, audits, chain of custody evaluation and data on mineral flows. With the exception of an initial evaluation of chain of custody evaluation in Rwanda, almost no full reports on mineral flows have been published in their entirety. The legal framework for certification that has been put in place within the region provides a basis for civil society actors to insist upon full transparency. It is only with this disclosure and openness that governments, businesses and civil society can bring about real and sustainable progress in creating conflict free supply chains. Clearly, an opportunity is presenting itself that resource governance advocates have not fully seized.