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Apple says latest conflict minerals review found no basis...
Marcus Mendes · 2026-05-29 · via 9to5Mac
Apple faces criminal complaints over Congo conflict minerals | Stock photo of mining vehicle

Apple has filed its annual conflict minerals disclosure with the SEC, detailing its supply chain checks across iPhone, Mac, and more. Here are the details.

Apple files annual conflict minerals disclosure with the SEC

For years, the issue of where Apple sources its minerals from, and whether they’re linked to human rights abuses or armed groups, has been a recurring source of scrutiny.

Last November, Apple was sued over alleged conflict mineral issues for the second time in recent years, with International Rights Advocates (IRAdvocates) claiming that the company’s supply chain still included minerals linked to child labor, forced labor, and armed groups in the Democratic Republic of Congo (DRC) and Rwanda.

In early 2024, IRAdvocates sued Apple and four other tech companies over alleged illegal cobalt sourcing, but the suit was later dismissed.

Apple, for its part, has always denied such allegations, in addition to publishing materials and reports on its supply chain, human rights, supplier code of conduct, and responsible sourcing through a transparency hub on its website.

Separate from those allegations, Apple is also subject to ongoing supply chain disclosure requirements, including annual conflict minerals filings with the SEC.

Apple made this filing today, covering the period from January 1 through December 31, 2025.

From the document:

Based on our due diligence, including analyzing the information provided by third-party audit programs, upstream traceability programs, independent reporting, and our suppliers, we found no reasonable basis for concluding that any smelters or refiners of 3TG identified in our supply chain as of December 31, 2025 directly or indirectly financed or benefited armed groups in the Democratic Republic of the Congo or an adjoining country (the “Covered Countries”). More information on Apple’s Responsible Minerals Sourcing program is available at apple.com/supply-chain/.

In the report, Apple says it required all suppliers that use tin, tantalum, tungsten, and gold (3TG) in the manufacturing of Apple products to submit an industry-standard Conflict Minerals Reporting Template. The products covered include “iPhone, Mac, iPad, AirPods, Apple TV, Apple Watch, Apple Vision Pro, Beats products, HomePod, HomePod mini, Apple Card, and all Apple accessories.”

Apple also says 100% of the 3TG smelters and refiners identified in its supply chain are required to participate in an independent third-party audit each year.

If those smelters or refiners are “unable or unwilling” to meet Apple’s standards, the company says it takes “necessary actions, through our suppliers, to terminate the applicable business relationships.”

One important caveat Apple makes in the report is that, since it “does not directly purchase, procure, or source primary minerals from mine sites,” the company relies on information from suppliers, smelters, refiners, and third-party audit programs to trace the origins of those minerals.

For this reason, Apple says it “cannot always determine the countries of origin of the 3TG actually contained” in its specific parts and products.

Apple says 3TG contained in its products may have originated from the DRC or adjoining countries, as well as from recycled and scrap sources, but stresses that it found no reasonable basis to conclude that any identified smelters or refiners financed or benefited armed groups in the region.

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