How to answer a responsible minerals questionnaire
Confirm the customer's mineral and component scope, trace suppliers towards smelters or refiners, and separate verified records from declarations and unknowns. Agree actions for missing evidence before signing; do not treat the questionnaire as proof of a universal UK legal duty. Cambridge China Bridge can help gather records from Chinese suppliers.
Separate policy, customer demands and legal claims
The UK Critical Minerals Strategy sets government expectations for respect for human rights, workers' rights and the environment throughout operations and supply chains. A separate government response supports voluntary human rights due diligence and promotes OECD minerals guidance in the extractives industry. Use these as context for responsible sourcing, rather than describing a customer's form as a universal Great Britain legal requirement.
Ask the customer which minerals, components, reporting period and supplier entities the questionnaire covers. Confirm whether answers must cover your whole business or only supplied products, and whether its requested evidence is a purchasing condition. If someone claims a legal obligation, ask for the applicable provision and check its scope separately before repeating that claim.
Trace the mineral beyond the assembly factory
Start with the ordered component, its material specification and the supplier's BOM where available. Ask which relevant minerals are present, which material or component suppliers provide them, and which smelters or refiners those suppliers identify. Request facility names, locations, identifiers where available, and documents linking the response to your components. Chinese assembly does not establish where minerals were mined.
For each link, record who supplied the information and what it actually covers. A company-wide facility list may include sources unrelated to your order. Follow the supplier batch-record guide for the factory-to-order link, then extend enquiries upstream. If a supplier cannot disclose a name, request controlled disclosure or an explanation; keep the link unresolved until supported.
Classify evidence before completing the form
Separate document-backed findings, supplier declarations and unresolved questions. Check names, component scope, reporting period and consistency across replies. A signed declaration is evidence of what the supplier stated; it does not independently establish mine origin. Use the material-certificate guide to check document relevance, while keeping material composition and responsible sourcing as separate questions.
Do not convert a blank answer into 'not present' or 'no risk'. Where the form offers only yes or no, ask the customer how to record uncertainty and attach a qualification. Keep an evidence register linking each answer to its document, limitation, responsible person and next action.
| Evidence received | What remains unresolved | Response action |
|---|---|---|
| Factory says minerals are absent | Basis of the statement and component coverage | Request the material specification and supporting supplier enquiry |
| Supplier provides a company-wide smelter list | Connection between listed facilities and your components | Label its scope and request product-specific clarification |
| Supplier names a refiner with an audit report | Report scope, findings and link to the supplied material | Check the report and retain any limitations |
Turn OECD-aligned checks into a working process
To work towards OECD alignment, use a documented, risk-based process rather than treating the completed questionnaire as the result. Assign an owner, communicate your sourcing policy and collect upstream information. Review evidence for conflict exposure, serious human rights concerns and inconsistent origin claims. Record your reasoning and escalate credible concerns to the person authorised to decide whether sourcing can continue.
Ask identified smelters or refiners, through suppliers where necessary, for relevant independent due diligence audit evidence. Review its scope, findings and unresolved issues rather than treating an audit label as proof for your batch. Agree corrective actions, review progress and retain a summary of your checks and outcomes. Describe this as work towards alignment unless you can substantiate a broader claim.
Submit a qualified answer and manage follow-up
A useful response says: 'Our reply covers the listed components and reporting period. We have received supplier declarations, but the upstream facility link remains unverified. We have requested supporting records and will update the response after review.' Adapt this wording to the actual evidence. Agree with the customer who accepts qualifications, which gaps need escalation and when an update is due before an authorised person signs.
Keep the submitted form, attachments, customer acceptance and follow-up correspondence together. Reopen the enquiry when materials, suppliers or upstream facilities change. Use the corrective-action closure guide before marking an action complete. Cambridge China Bridge's staff in China can pursue supplier records and clarification; report explicitly where that work still leaves upstream evidence missing.
Frequently asked questions
Is a customer's minerals questionnaire UK law?
Do not infer a universal legal duty from a customer form. Clarify its purchasing requirements and ask for the applicable provision if it claims a legal obligation. Government support for voluntary due diligence is separate context.
Does a Chinese factory address prove mineral origin?
No. Trace the component's material suppliers towards smelters or refiners and request origin records where available. Keep the assembly location separate from the mineral's extraction and processing locations.
What if my supplier cannot identify the smelter?
Record the link as unknown, retain the supplier's explanation and request upstream follow-up. Agree a qualified response and an action plan with the customer rather than signing an unsupported assurance.
Does a smelter audit prove my components are responsible?
Check what the audit covers, its findings and whether the facility is linked to your components. Retain limitations and follow-up actions. An audit label alone does not establish the sourcing history of your batch.