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Apple has filed its annual conflict minerals disclosure with the U.S. Securities and Exchange Commission (SEC) and reached a clear conclusion: there is no reasonable evidence that suppliers have financed armed groups in the Congo. At the same time, the company acknowledges a structural limitation that has plagued the issue for years.
The origins of the raw materials for Apple's devices, and whether these are linked to human rights abuses or armed conflicts, have long been a recurring point of criticism. Regardless of specific allegations, Apple is subject to regulatory disclosure requirements, including an annual conflict minerals report to the SEC. The company has now submitted this report for the period from January 1 to December 31, 2025. According to the company, some of the metals used in Apple products come from recycled and reclaimed sources – an area where Apple recently reported a new record for the percentage of recycled materials. However, the latest report also reveals the limitations of tracing even with the greatest effort.
What the test revealed
The report focuses on the so-called 3TG metals: tin, tantalum, tungsten, and gold. Based on its due diligence – including the evaluation of data from independent audit programs, upstream supply chain traceability programs, independent reports, and information from its own suppliers – Apple stated that it found no reasonable evidence to suggest that any of the smelters or refineries identified in its supply chain for these metals directly or indirectly financed or benefited from armed groups in the Democratic Republic of Congo or any adjacent country as of December 31, 2025.
The disclosure covers almost the entire product portfolio. According to the information provided, it includes iPhone, Mac, iPad, AirPods, Apple TV, Apple Watch, Apple Vision Pro, Beats products, HomePod, HomePod mini, Apple Card, and all Apple accessories.
How Apple controls its supply chain
To make this statement, Apple relies on a standardized reporting procedure. All suppliers who use tin, tantalum, tungsten, or gold in the manufacture of Apple products must therefore complete an industry-standard form for reporting conflict minerals.
In addition, there is an audit requirement: According to Apple, 100 percent of the smelters and refineries identified in the supply chain for these metals must participate in an independent third-party audit annually. If a smelter or refinery does not meet the standards or is unwilling to do so, Apple states that it will take the necessary steps through the respective suppliers to terminate the business relationship in question.
The limits of tracing
As comprehensive as the verification system is described, Apple itself identifies a crucial limitation. Since the company does not directly purchase, procure, or source the raw materials from the mines, it relies on information from suppliers, smelters, refineries, and independent audit programs to determine their origin.
For this reason, Apple states that it cannot always determine the exact country of origin of the 3TG metals contained in individual components and products. These could come from the Congo or neighboring countries, as well as from recycled and reused sources. Despite this open question regarding the specific origin, the company maintains its finding that there is no substantiated evidence of the identified smelters or refineries financing armed groups.
Complaints and persistent criticism
The report comes against the backdrop of ongoing legal disputes. In November 2025, Apple was sued again in connection with conflict minerals. The human rights organization International Rights Advocates accuses the company of continuing to include minerals in its supply chain that are linked to child labor, forced labor, and armed groups in the Democratic Republic of Congo and Rwanda.
As early as 2024, the same organization sued Apple and four other technology companies for allegedly illegal cobalt procurement; this lawsuit was later dismissed. Apple has consistently denied such allegations and regularly publishes materials and reports on its supply chain, human rights, supplier code of conduct, and responsible sourcing via a dedicated transparency section on its website.
Apple: Due diligence with built-in limits
The report illustrates a tension that cannot be resolved through audits alone. On the one hand, there is a meticulously documented auditing system with standardized reporting, annual audits, and the announced termination of partnerships with those who do not comply. On the other hand, there is the admission that the origin of the metals cannot be fully traced back to the mine because Apple itself is not involved at the beginning of this chain.
Critics and plaintiffs exploit this gap, while Apple emphasizes the validity of independent audits. For consumers, this means that while the annual report documents considerable monitoring efforts, it cannot, by its very nature, definitively answer the question of the exact origin of every single gram – a fact that is likely to remain relevant for years to come. (Image: Shutterstock / vision-photo)
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