Switzerland: New Ordinance on Conflict Minerals and Child Labor

The "Ordinance on Due Diligence and Transparency in the Sectors of Minerals and Metals from Conflict Areas and Child Labour" (VSoTr) came into force in Switzerland on January 1, 2022. Affected companies are granted a transition period of one year.

Among others, the new regulation provides for comprehensive due diligence and reporting obligations with regard to conflict minerals and child labor. Companies based in Switzerland are affected by the new requirements, in case they

•  import or process minerals and metals containing tin, tantalum, tungsten or gold from conflict and high-risk areas,
•  exceed the annual import and processing quantities in the process,
• offer products and services for which there is a reasonable suspicion of child labor.

There are exemptions for small and medium-sized enterprises, unless products or services are obviously produced or provided for through child labor.

With the new "Ordinance on Due Diligence and Transparency Regarding Minerals and Metals from Conflict-Affected Areas and Child Labor", Switzerland is aligning its policies with current rules and regulations, such as the EU Conflict Minerals Regulation (EU 2017/821) and corresponding OECD guidelines, as well as the Child Labor Due Diligence Act in the Netherlands.