Materialise Tracks Minerals from Conflict Zones, Reveals 3D Printing Blind Spot

Highlighting a rare industry effort, Materialise (Nasdaq: MTLS)  has filed a specialized disclosure (Form SD) with the US Securities and Exchange Commission (SEC), describing how it monitors the use of conflict minerals commonly known as 3TG like tin, tantalum, tungsten, and gold, across its 3D printing operations. These materials, commonly used in electronics and advanced manufacturing, are sometimes sourced from conflict-affected regions like the Democratic Republic of the Congo.

Although the company doesn’t source raw materials directly, it surveyed its suppliers to trace the origin of these minerals. The findings revealed that some materials may have originated from high-risk regions, but suppliers often could not confirm their exact sources.

In response, Materialise outlined a strategy to strengthen transparency, including supplier engagement and alignment with international due diligence frameworks like the Organisation for Economic Co-operation and Development (OECD) guidelines. This is a widely used set of rules that help companies check where their minerals come from and make sure they’re not linked to conflict or abuse.

This rare look into ethical sourcing in the additive manufacturing (AM) sector raises important questions about how 3D printing companies manage global supply chains. Materialise’s strategy reflects a growing, though still unusual, effort in the industry to bring more transparency to sourcing practices.

Indeed, most private and non-US firms aren’t required to file these disclosures. Still, the issue is becoming more relevant as 3D printing moves deeper into sectors like aerospace, medical devices, and electronics—industries where supply chain rules are stricter. Materialise’s transparency brings attention to a part of the 3D printing world that doesn’t often make headlines: how materials are sourced, and whether that process supports ethical practices. In doing so, it also exposes what remains a blind spot in the industry, not in compliance but in conversation, transparency, and public accountability.

Under US law (specifically Rule 13p-1 of the Securities Exchange Act), companies must report whether the 3TG metals used in their products come from the Democratic Republic of the Congo or nearby countries, where mining has been linked to violence and human rights abuses. While the rule focuses on the Congo region, other areas like Myanmar, Indonesia, and parts of South America have also raised concerns over similar issues.

From 2023 through 2025, virtually all major publicly traded 3D printing companies—including 3D Systems, Stratasys, Desktop Metal, Velo3D, Materialise, Shapeways, voxeljet, and Markforged—filed the required Form SD disclosures. Those whose products contain 3TG metals also submitted Conflict Minerals Reports (CMRs) describing efforts to trace the source of these materials. While no company in this sector avoided filing, the level of detail and transparency varied widely. Smaller service-oriented firms like Shapeways (now owned by WVS International) and foreign issuers such as Materialise and voxeljet were not exempt.

Most companies explicitly reference the OECD Due Diligence Guidance as the framework for their conflict minerals program. For example, 3D Systems states that its due diligence measures were “designed to conform, in all material respects, with the … OECD’s Due Diligence Guidance.” Meanwhile, Stratasys similarly outlines its process according to the five steps defined by the OECD.

This shows that many companies in the 3D printing industry are taking conflict minerals rules seriously and trying to follow international standards. Those that filed a Conflict Minerals Report said they had internal teams handling the process, checked for risks by surveying their suppliers, and took steps to deal with problems, like following up or helping suppliers understand the rules.

Bigger companies like 3D Systems and Stratasys said they review third-party audit data on the smelters in their supply chain and publish their findings every year. They include sections corresponding to each OECD step, discuss the use of tools like the Responsible Minerals Initiative (RMI’s) smelter database, and, in 3D Systems’ case, include tables of smelters and countries of origin identified. They also talk about follow-up actions, such as 3D Systems’ “escalation plan” for red-flag smelters.

Smaller companies followed similar steps, just on a smaller scale. For example, Shapeways asked all its key suppliers to fill out forms about where their materials came from and then checked those answers against a trusted list of approved smelters.

Every company that filed a CMR reached out to its supply chain to gather information on mineral sourcing. For example, 3D Systems reported that it encourages suppliers to use certified conflict-free smelters, while Stratasys and Shapeways reported 100% or near-100% response rates from their surveyed suppliers.

In short, public 3D printing companies that filed full CMRs did so because they couldn’t be certain about the source of some materials. Their detailed reports—especially compared to those in other sectors—suggest the industry is making a serious effort to meet the standards.