Chapter 1. Introduction

The report examines the role of traceability in strengthening the sustainability, resilience and security of critical mineral supply chains as demand accelerates due to the clean energy transition. Mineral demand is expected to double by 2030 under stated policies and nearly triple under more ambitious climate scenarios, implying significant expansion of mining and processing. These developments heighten environmental, social and governance (ESG) risks, particularly in conflict-affected and high-risk regions. Traceability is positioned as a tool to support responsible sourcing and due diligence, not as a substitute for it.

Chapter 2. What is traceability?

Traceability is defined as the ability to identify and verify a product’s origin, geographical path, chain of custody and physical transformation over time through documented records. In mineral supply chains, this may include linking ESG data—such as greenhouse gas emissions, human rights risks and governance indicators—to materials as they move from extraction to end use. The report clarifies that traceability supports, but does not replace, OECD-aligned due diligence processes, which remain essential for identifying, preventing and mitigating adverse impacts.

Chapter 3. Policies, regulations and market requirements on traceability

Policy and regulatory measures encouraging traceability are increasing globally, often indirectly through due diligence, reporting and trade requirements. Examples include the EU Corporate Sustainability Reporting Directive, the Corporate Sustainability Due Diligence Directive, Canada’s forced and child labour reporting law, and the EU Critical Raw Materials Act. These frameworks require varying levels of proof, from statements of intention to transaction-level evidence. Regulators have adopted pragmatic flexibility where tracing is impracticable, recognising cost, data availability and infrastructure constraints. Public funding, such as EU support of approximately EUR 11 million for digital traceability projects, is contributing to system development and experimentation.

Chapter 4. Components of an effective mineral traceability system: A toolkit

The report identifies four core components of effective traceability systems: technical infrastructure, standardised and reliable data collection, supply chain collaboration, and governance with verification. Systems must balance robustness, cost and practicality, and ensure interoperability across actors and jurisdictions. Tools range from physical tagging and digital ledgers to blockchain and scientific verification methods, each with trade-offs in scalability and expense. Strong governance, independent audits and multiple verification layers are highlighted as necessary to address fraud, corruption and data reliability risks, particularly where materials are blended or recycled.

Chapter 5. Considerations for energy transition minerals

Traceability challenges vary significantly by mineral due to differences in supply concentration, processing complexity and ESG risk exposure. Cobalt supply is highly concentrated, with artisanal and small-scale mining accounting for an estimated 5–15% of global output. Graphite, nickel and rare earth processing is concentrated in markets with limited transparency, while copper and lithium supply chains are complex and globally dispersed. The report concludes that full traceability for all minerals would be costly and inefficient, recommending a risk-based approach that prioritises high-risk minerals and supply chain segments.

Chapter 6. Roadmap for increasing mineral traceability

The report outlines an eight-step roadmap for policymakers, including clarifying policy objectives, prioritising products and operators, defining data requirements, promoting interoperability, establishing trust mechanisms, creating incentives, and engaging internationally. Governments are encouraged to align traceability with broader due diligence goals, allow flexibility where tracing is not proportionate, and avoid excessive burdens that could exclude smaller or artisanal actors. Traceability should be used to inform risk management and improvement, rather than as a narrow compliance exercise.