What is 3TG Conflict Material? A Guide for PCB Manufacturers & Buyers
In the world of electronics and PCB manufacturing and assembly, responsible sourcing is a growing priority. Regulations such as the U.S. Dodd‑Frank Act Section 1502 and the EU Conflict Minerals Regulation require companies to know exactly where their raw materials come from – especially 3TG conflict material.
But what does 3TG stand for? Why are these materials considered “conflict” materials? And how does this affect your printed circuit board supply chain?
But what does 3TG stand for? Why are these materials considered “conflict” materials? And how does this affect your printed circuit board supply chain?
1. What Does 3TG Stand For?
3TG is an acronym for four metals and their ores:
Letter
Metal
Common Uses in PCBs
T
Tin (Sn)
Solder paste, lead plating, surface finish
T
Tantalum (Ta)
Capacitors, high‑power resistors
T
Tungsten (W)
Via fill, sputtering targets, WF₆ gas
G
Gold (Au)
Wire bonding, ENIG surface finish, connectors
These four metals are collectively referred to as conflict minerals under international regulations.
2. What Makes 3TG a “Conflict Material”?
A 3TG mineral becomes conflict material when it is mined or traded in Conflict‑Affected and High‑Risk Areas (CAHRAs) – primarily the Democratic Republic of the Congo (DRC) and its nine neighboring countries:
These four metals are collectively referred to as conflict minerals under international regulations.
- Angola
- Burundi
- Central African Republic
- Republic of Congo
- Rwanda
- South Sudan
- Tanzania
- Uganda
- Zambia
If the extraction or trade of tin, tantalum, tungsten, or gold finances armed conflict, child labor, or human rights abuses, it is classified as conflict material.
- Important: Not all 3TG is conflict material. A 3TG mineral from a certified conflict‑free smelter (e.g., in China, Australia, or Europe) is perfectly acceptable.
3. Why Does 3TG Conflict Material Matter for PCB Manufacturing?
You might ask: Why should a PCB manufacturer or buyer care?
- Regulatory Compliance
- Dodd‑Frank Act (USA) requires public companies to disclose use of 3TG from DRC region.
- EU Regulation 2017/821 requires EU importers to perform due diligence.
- Customer Requirements
Major brands in automotive, medical, aerospace, and consumer electronics demand that their PCB suppliers provide a CMRT (Conflict Minerals Reporting Template). Non‑compliance can lose you contracts
- Corporate Social Responsibility (CSR)
Ethical sourcing builds trust with customers, investors, and the public.
- Risk Mitigation
Using conflict materials exposes your company to legal liability, reputational damage, and supply chain disruption.
4. How 3TG Minerals Are Used in PCBs
Understanding where 3TG appears helps you map your supply chain.
Tin (Sn) – The Most Common
- Solder paste (the primary use in PCB assembly)
- HASL (Hot Air Solder Leveling) surface finish
- Component lead plating
Tantalum (Ta) – In Components
Tantalum capacitors (widely used in power supplies, medical devices)
High‑power resistors
Tungsten (W) – In Advanced PCBs
Via fill contacts
Sputtering targets for thin‑film deposition
Tungsten hexafluoride (WF₆) gas in semiconductor processing
Gold (Au) – High‑Reliability PCBs
Wire bonding (connecting silicon chips)
ENIG (Electroless Nickel Immersion Gold) surface finish
Gold fingers (edge connectors)
5. Key Regulations & Standards
Dodd‑Frank Act Section 1502 (USA)
- Applies to SEC registrants
- Requires RCOI (Reasonable Country of Origin Inquiry)
- Mandates OECD‑aligned due diligence
- Filing of Form SD and possible Conflict Minerals Report
EU Conflict Minerals Regulation (2017/821)
- Applies to EU importers of 3TG minerals
- Requires supply chain due diligence and reporting
OECD Due Diligence Guidance
The internationally accepted framework – 5 steps:
- Establish management systems
- Identify and assess supply chain risks
- Respond to identified risks
- Audit supply chain due diligence
- Report annually
6. The CMRT: Conflict Minerals Reporting Template
The CMRT is the industry standard tool for collecting 3TG sourcing information, developed by the Responsible Minerals Initiative (RMI) .
What the CMRT Captures
- Smelter and refiner names
- Country of origin of 3TG
- RMAP conformance status
- Supplier due diligence practices
Latest Version
As of 2026, use CMRT 6.5 or later.
7. RMAP Conformance – The Gold Standard
RMAP (Responsible Minerals Assurance Process) is the RMI’s audit program for smelters.
- RMAP Conformant – Fully audited and conflict‑free
- RMAP Eligible – Committed to becoming conformant
- Non‑Conformant – Not acceptable for responsible sourcing
Leading PCB manufacturers source only from RMAP conformant smelters.
8. How WELLER Ensures 3TG Compliance
At WELLER PCB, we take conflict minerals seriously. Our approach includes:
Leading PCB manufacturers source only from RMAP conformant smelters.
- Formal Conflict Minerals Policy – publicly available and enforced
- Supplier CMRT Collection – every material supplier must provide a valid CMRT
- OECD‑Aligned Due Diligence – risk assessment and corrective actions
- RMAP Conformant Sourcing – we prioritize smelters certified by RMI
- Customer Transparency – we provide CMRT declarations upon request
When you order PCBs and assemblies from WELLER, you get both technical excellence and ethical assurance.
9. Frequently Asked Questions (FAQ)
1. Are all 3TG minerals considered conflict materials?
A: No. Only those sourced from conflict‑affected regions that finance armed conflict. Conflict‑free 3TG is perfectly acceptable.
2. Does WELLER use 3TG in its PCBs?
A: Yes, like all PCB manufacturers, we use tin in solder paste and gold in surface finishes. But we source only from conflict‑free, RMAP conformant smelters.
3. What is the difference between CMRT and EMRT?
A: CMRT covers 3TG (tin, tantalum, tungsten, gold). EMRT adds cobalt, mica, and lithium.
4. Can a small PCB buyer request conflict minerals data?
A: Absolutely. Contact your supplier and ask for their CMRT or a conflict minerals declaration. WELLER provides this to all customers.
5. What happens if a WELLER supplier uses a non‑conformant smelter?
A: We require corrective action. If unresolved, we replace the supplier or material.
10. WELLER’s Commitment
We believe that high‑quality PCBs should never come at the cost of human rights or regional stability.
Our promise:
- 100% RMAP conformant sourcing for all 3TG where feasible
- Annual CMRT updates for our manufacturing operations
- Full transparency for our customers
Conclusion
3TG conflict material refers to tin, tantalum, tungsten, and gold that originate from conflict‑affected regions, financing violence or human rights abuses. Regulations like the Dodd‑Frank Act and EU rules require supply chain due diligence.
For PCB manufacturers and buyers, understanding 3TG is essential for compliance, customer trust, and corporate responsibility.
- Customer Transparency – we provide CMRT declarations upon request
Choose WELLER for conflict‑free, high‑reliability PCBs.
Request a quote or contact our compliance team for CMRT documentation.
Related Resources from WELLER
- Conflict Minerals Policy – full policy document
- Supplier Quality Requirements – how we audit suppliers
- PCB Manufacturing Specifications – technical standards
- Standard Terms for PCB Assembly – commercial conditions
References
- OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict‑Affected and High‑Risk Areas (3rd Edition)
- U.S. Dodd‑Frank Wall Street Reform and Consumer Protection Act, Section 1502
- Responsible Minerals Initiative (RMI) – CMRT and RMAP
- EU Regulation 2017/821 – Conflict Minerals Regulation