Conflict Minerals Disclosure pursuant to Regulation (EU) 2017/821
RVT publishes this report in fulfillment of the disclosure obligations under Regulation (EU) 2017/821 of the European Parliament and of the Council of 17 May 2017. This declaration is made pursuant to Article 7(3) regarding compliance with supply chain due diligence obligations for Union importers of conflict minerals such as tin, tantalum, tungsten, their ores, and gold originating from conflict-affected and high-risk areas.
Company Information
RVT Process Equipment GmbH
Im Gries 15
96364 Marktrodach
Germany
Phone: +49 9261 55235-0
E-Mail: [email protected]
Website: https://www.rvtpe.com
Reporting Year: 2025
Relevant Imports
During the reporting year, the company imported tantalum semi-finished products (HS Code 81039010) from China on a one-time basis with a total weight of 259 kg. As a result of this import, the company fell within the scope of Regulation (EU) 2017/821 during the reporting year.
No further imports of tantalum, tin, tungsten, gold, or their ores falling within the scope of Regulation (EU) 2017/821 were carried out by RVT during the reporting year.
The reporting obligation results solely from the aforementioned one-time import. It was only after receiving correspondence from DEKSOR (German Competent Authority for EU Due Diligence Obligations in Raw Material Supply Chains) that the company became aware that this import was subject to the requirements of Regulation (EU) 2017/821. Until that point, the company had assumed that, due to the nature and volume of its procurement activities, no obligations under the Regulation existed. After becoming aware of the reporting obligation, the requirements of the Regulation were reviewed and appropriate internal measures were initiated.
Management System (Article 4)
At the time of the import, no dedicated management system existed to fulfill the due diligence obligations under Regulation (EU) 2017/821. However, the company maintains a certified quality management system in accordance with ISO 9001 and an environmental management system in accordance with ISO 14001. Procurement and supply chain documents relevant to the import were recorded and retained within the framework of the company's existing business processes. For the relevant shipment, the available supplier and purchase information was documented and archived.
Risk Management (Article 5)
The shipment was supplied by a commercial supplier located in China. At the time of import, no separate documented risk assessment process was carried out in accordance with the requirements of Regulation (EU) 2017/821. To the company's knowledge, no information indicating risks within the supply chain was available at that time. However, a more detailed assessment in accordance with the Regulation was not documented during the reporting year. As this was a one-time import, no permanent sourcing program for tantalum was established.
Independent Third-Party Audits (Article 6)
No independent third-party audit or assessment in accordance with Article 6 of Regulation (EU) 2017/821 was conducted for the relevant import.
Summary
The company reviewed the available information relating to the supply chain of the imported tantalum products and documented the supplier information available at the time. The supplier and procurement information available at the time of import was documented accordingly. Additional information regarding the origin of the material and the upstream supply chain has subsequently been requested from the supplier and will be evaluated and documented upon receipt.
Measures Taken
Following notification by the German Competent Authority for EU Due Diligence Obligations in Raw Material Supply Chains (DEKSOR), the company reviewed the requirements of Regulation (EU) 2017/821 and published the present disclosure. Furthermore, additional information has been requested from the supplier regarding the origin of the material, the upstream supply chain, existing responsible sourcing documentation, and conflict minerals compliance documentation. For future imports of relevant minerals, a prior assessment will be conducted to determine whether the thresholds and requirements of Regulation (EU) 2017/821 apply.
The company has reviewed and adapted its internal procurement and compliance processes in order to identify at an early stage whether future imports fall within the scope of Regulation (EU) 2017/821.
In particular, the company will henceforth:
- regularly review relevant customs tariff classifications,
- monitor import volumes,
- document supplier information,
- obtain required supply chain documentation,
- continuously monitor regulatory developments relating to due diligence obligations.
Company Declaration
The company confirms that tantalum semi-finished products were imported on a one-time basis during the reporting year.
This report has been prepared retrospectively.
The company will continue to consider and comply with the requirements of Regulation (EU) 2017/821 and maintain the organizational measures necessary to fulfill these obligations in the future.
Marktrodach, 24 July 2026
(Date of Publication)
RVT Process Equipment GmbH
