# ITSCI The bag-and-tag traceability scheme that was supposed to make conflict-minerals due diligence work on the ground in the Great Lakes, and that has been credibly accused of doing the opposite. ## What it is Created in **2009** by the tin industry's own trade body (ITRI, now the International Tin Association), later joined by the Tantalum-Niobium International Study Center, and implemented in the field by the NGO **Pact**. ITSCI is the dominant upstream scheme for tin, tantalum and tungsten in the DRC, Rwanda and Burundi: minerals are tagged at validated mine sites, logged through the chain of custody, and arrive at smelters with a documented origin. Downstream compliance with [[Dodd-Frank Section 1502]] and the EU regulation has in practice rested on that documentation. ITSCI reported around 2,500 monitored sites and 1,325 logged incidents in 2021. ## The Laundromat [[Global Witness]]'s **April 2022** investigation alleged that the tagging system was laundering minerals from armed-group-controlled and child-labour sites into international supply chains. Its specific findings: - In Nzibira, South Kivu, only **20% of tagged material** in one quarter came from validated mines. A Pact consultant had found **97%** unvalidated in a 2016 sample. - At Lubuhu, cassiterite was tagged at **fifteen times** the production capacity of the two validated local mines. - A senior ITSCI figure in Rwanda estimated that **only about 10% of Rwanda's exported minerals had actually been extracted there.** - Traced routes reached Apple, Intel, Samsung, Nokia, Motorola and Tesla. Two smelters that likely sourced conflict minerals remained certified. The structural criticism is the one that matters most: **the trade association representing the buyers operates the compliance scheme.** ## The response, and the consequence ITSCI called the findings sensationalised and selective, noted that it employs 120 permanent local field staff against Global Witness's 90 interviews, and made a point that is legally accurate and rhetorically devastating: **ITSCI is not a certification programme and does not guarantee "conflict-free" minerals.** If true, then a decade of downstream compliance claims rested on a document that never promised what buyers treated it as promising. The Responsible Minerals Initiative let ITSCI's recognition **lapse on 31 October 2022**; from 1 July 2023 auditees relying on ITSCI without independent evidence were cited non-conformant. ITSCI paused its own reapplication in December 2023, and RMI paused consideration in July 2024. ## Where it stands ITSCI is still operating and still the dominant scheme in the region. It suspended tagging in parts of North and South Kivu from **28 February 2025** as [[M23]] advanced — leaving a hole in the traceability regime precisely where the conflict is. It logged 70 incidents of tag misuse in 2025 and has suspended or expelled six coltan exporters since 2024. It also disputes the UN's smuggling volumes, saying it observed no export spike matching the alleged 120 tonnes a month. > [!warning] Operating rule for this vault > Every downstream "conflict-free" claim resting on ITSCI or RMI certification should be treated as **unverified** until the Rwanda border problem is solved. It has not been solved. ## See also [[Global Witness]] · [[Dodd-Frank Section 1502]] · [[OECD Due Diligence Guidance]] · [[Rwanda]] · [[Conflict Minerals Ecosystem]]