Insights from Industry Actors on Chain-of-Custody Implementation in the Mineral Supply Chains

A chain of custody (CoC) system, in which actors across the supply chain are certified and are involved in activities starting from extraction to the manufacture of the final product, will help to support the creation of a chain of verification for responsible practices and, at the same time, ensure that the products can be traced and verified to be from certified sources. This CoC system is increasingly being addressed in regulations and international standards to foster environmental, social, and governance (ESG) due diligence and responsible sourcing practices. However, despite its advantages, adoption remains slow and uneven. This suggests that there are barriers to practical implementation by industry actors. So, the aim of this research is to understand industry actors’ perspectives on the implementation of a CoC system in mineral supply chains and to identify the factors that influence its adoption. By doing so, this study presents insights from industry actors and formulates more realistic expectations for the uptake of CoC systems, as well as the aspects policymakers and standard-setters should consider when designing or promoting them. To capture their views, semi-structured interviews were conducted from June to September 2025, with 10 actors across the upstream, midstream, and downstream stages of the supply chain in different regions. This study finds a gap between what regulatory bodies expect and industry actors’ capacity to implement such a system, due to factors including limited awareness of the CoC system, perceived value of claims, a lack of guidance on implementation, technology immaturity, and supplier engagement challenges.