Due diligence and transparency obligations in the area of minerals and metals from conflict zones and child labour as well as non-financial reporting obligations came into force in Switzerland on January 1, 2024. On March 15, 2024, the Council of the European Union approved the Corporate Sustainability Due Diligence Directive (CS3D), which will affect both EU and non-EU companies with a significant turnover in the EU. In an increasingly complicated legislative framework, businesses must have the necessary tools in place to meet legal requirements and conduct focused due diligence.

Swiss Regulations

Following the rejection in 2020 of the Swiss popular initiative on mandatory environmental and human rights due diligence (commonly referred to as the “Responsible Business Initiative, RBI)”, the counterproposal sponsored by the Swiss Federal Council in the form of an amendment to the Swiss Code of Obligations came into force on January 1, 2024, providing non-financial reporting obligations as well as due diligence and transparency obligations in the area of minerals and metals from conflict zones and child labor.

Non-financial reporting obligations

As per Ordinance on Climate Disclosure (Italian version), starting from the fiscal year 2023, public companies, banks and insurance companies with 500 or more employees and at least CHF 20 million in total assets or more than CHF 40 million in turnover are obliged to report on non-financial matters and disclose publicly environmental, social, labor, human rights and corruption risks, as well as steps taken to address them (see Articles 964a-964c of the Code of Obligations).

Companies fulfilling these requirements but are controlled by a company falling within the abovementioned scope of application or having to prepare an equivalent report under foreign law, are exempt from the non-financial reporting obligations.

Due diligence and transparency in relation to metals and minerals from conflict zones and child labour

Companies exposed to risks in the sensitive areas of child labor and minerals from conflict zones must meet specific due diligence and reporting requirements if the thresholds for the import and processing of minerals and metals from conflict zones, set out in Annex I of the Ordinance on Due Diligence and Transparency Obligations in relation to Minerals and Metals from Conflict-Affected Areas and Child Labor (DDTrO) are exceeded (also see Articles 964k-964l of the Code of Obligations).

The minerals category includes ores, gold and concentrates containing tin, tantalum or tungsten. Metals are those containing or consisting of tin, tantalum, tungsten, or gold – also in form of by-products.

Due diligence obligations include implementing and maintaining a management system as well as establishing a supply chain policy and a supply chain traceability system.

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas and the Regulation (EU) 2017/821 serve as reference.

The Swiss Federal Council is now analyzing the implications of the European Union’s Corporate Sustainability Due Diligence Directive (CS3D) for Swiss companies and is expected to decide on the next steps to take once the final version of the CS3D is released and the mechanisms by which the EU Member States will implement this Directive are known.

The EU CS3D

Following two failed attempts to gain approval, on March 15, 2024, the Council of the EU adopted a heavily watered-down version of the Corporate Sustainability Due Diligence Directive (CS3D), requiring EU and non-EU companies with activities in the EU to carefully manage social and environmental impacts throughout their entire supply chain. The next stage is for the EU Parliament to approve this “compromise text” (likely in April 20024). If approved, the CS3D regulations will then apply to companies with at least 1’000 employees and a turnover in the EU of €450 million, rather than 500 employees and a turnover of €150 million, as previously proposed by the Commission. Lower thresholds for high-impact businesses, such as textile manufacturing, food production, mineral extraction, and construction, have been eliminated.

Legislation in some Member States, such as Germany (Supply Chain Due Diligence Act or “Lieferkettengesetz”), France (Duty of Diligence Act or “Loi sur le devoir de vigilance”) or the Netherlands (Child Labor Due Diligence Act, or “Wet Zorgplicht Kinderarbeid”, and the draft supply chain law), will need to be adapted to CS3D. Businesses would be expected to be far more attentive when it comes to suppliers.

What is certain is that the legislative landscape regarding these topics is growing more complex and the impact on commodity trading companies (among others) will be significant in the coming years. The LCTA members are offered the opportunity to further discuss this with the Total Quality Assurance Intertek and the human rights consultancy firm focusright next April 17, 2024 and equip themselves with the appropriate tools to meet the legal requirements and conduct focused due diligence.

CLICK HERE TO LEARN MORE ABOUT THE EVENT

Source: SUISSENÉGOCE, completed by LCTA. This article was originally published on the LCTA website on March 14, 2024 and edited on March 19, 2024.



On January 31, 2024, the Federal Council enacted additional measures against Russia, effectively adopting the EU’s 12th sanctions package.

The new provisions include, among others, a gradual ban on the purchase and import of Russian diamonds, further measures to support the enforcement of the price cap for Russian crude oil and petroleum products and combat its circumvention, and notification and authorization requirements for the sale of tankers that can be used to circumvent the oil price cap.

As of March 20, 2024, exporters will be required to contractually prohibit their partners established outside the EEA or a partner country (Australia, Canada, South Korea, Japan, Norway, New Zealand, the United Kingdom, and the United States) from re-exporting goods listed in Annexes 3 and 19 of the Ordinance on Measures connected with the Situation in Ukraine, as well as high-priority goods listed in Annex 31, to Russia or for use there. In the event of a violation, appropriate corrective steps must be specified in the contract. Such infractions must be immediately reported to the State Secretariat for Economic Affairs (SECO). The obligation does not apply to business contracts signed before February 1, 2024 and completed by December 20, 2024, or contracts that have expired, whichever occurs first.

The Ordinance imposing measures in relation to the situation in Ukraine as amended to February 1, 2024 can be found here (Italian version).

SECO has also updated its interpretative paper on sanctions with special reference (but not limited) to:

  • compliance with Article 12b(4)(b) and (5) (crude oil and petroleum products): SECO refers to the EU Commission’s FAQs on the implementation of EU Council Regulations 269/2014 and 833/2014, in particular the explanations contained in Chapter E “Energy”, point 5 “Oil Price Cap”, section 7 “Attestations, recordkeeping and itemised ancillary costs”. These explanations show what information and documents are appropriate as evidence;
  • proof of the third country of origin of the steel articles listed in Annex 17 used as inputs (Art. 14a): beginning March 1, 2024, this proof must be included as a document (document code Y824) under the heading “Documents” in the customs declaration. The document must be presented on request to the Federal Office for Customs and Border Security (FOCBS), together with the relevant customs documentation.

SECO’s interpretative paper (FAQ) is available online (Italian Version).



By 2027, the United Kingdom (UK) will have implemented its own carbon border adjustment mechanism (CBAM).

On December 18, 2023, U.K. Chancellor of the Exchequer Jeremy Hunt announced in a press statement that a fee will be levied on carbon-intensive products such as iron, steel, aluminum, fertilizer, hydrogen, ceramics, glass and cement imported from Third countries. The CBAM’s design and delivery will be subject to further consultation in 2024, including an exact list of goods in scope. However, a broader reach than its European counterpart is already emerging.

The liability applied by the CBAM will be determined by the intensity of the imported good’s greenhouse gas emissions and the gap between the carbon price applied in the country of origin (if any) and the carbon price that would have been applied had the good been produced in the UK.

Source: Factsheet: UK Carbon Border Adjustment Mechanism

The CBAM liability will fall directly on the importer of the products within scope of the UK CBAM, based on the emissions embodied in the imported goods. This system will not require the purchase or exchange of emissions certificates, but will cooperate in conjunction with the UK Emissions Trading Scheme (ETS) to ensure that imported products are priced at a carbon price comparable to that supported by British production, thus reducing the risk of carbon relocalization.

This article was originally published in Italian on www.cc-ti.ch on January 18, 2024



At the Ordinary General Meeting held on December 20, 2023, the LCTA Executive Board proposed Simone Knobloch, COO of Valcambi SA, Alessandro Odoni, Finance Director of Flame SA and Marco Passalia, Partner of Enet Energy SA be elected as new Executive Board Members. Monica Zurfluh, who officially took office beginning of November, was introduced as new Secretary General. 

The Ordinary General Meeting held in December 2023 elected new Board members in accordance with the Executive Board’s proposal: Simone Knobloch, COO of Valcambi and Alessandro Odoni, Finance Director of Flame SA.  

Michael Mesaric, CEO of Valcambi SA, and Riccardo Talenti, Charter & Operations Manager at Flame SA had previously announced decision to resign from the Executive Board in connection with the General Meeting. Both had been active members of the Executive Board since LCTA’s formation, and the Executive Board recognized them for their contributions to shaping the Association and supporting its interests. 

Marco Passalia, Partner of Enet Energy SA, opted to step down as Secretary General and relinquish operational responsibilities. Recognizing Marco Passalia’s critical role as co-initiator and engine of the Association, the Executive Board proposed he join the Board as 14th member in derogation from the statutes (the temporary increase in the number of Board Members will be reduced again to 13 during 2024 following the complete integration of Credit Suisse into UBS).  

Marco Passalia received special distinction for his achievements since the Associations’ inception in 2010. His lobbying activities at the cantonal and federal levels as well as the organization of several international events and conferences have been critical to the Ticino hub’s positioning and consolidation as Switzerland’s third-largest commodity trading center after Geneva and Zurich, while the launch of both the CAS in Commodity Professional in collaboration with the Zug Commodity Association (ZCA) and the Hochschule Luzern, and the most recent Certified Commodity Trading Specialist training in collaboration with Alma Impact as well as numerous short-term courses contributed to the members’ skills and knowledge, ultimately attracting and retaining talents. 

The General Meeting welcomed Monica Zurfluh, Head of International Trade of the Ticino Chamber of Commerce and Industry (Cc-Ti), as the new Secretary General of LCTA. Monica Zurfluh officially took up her new function on November 1st, 2023. 

As of the end of 2023, LCTA counted 48 active members. 



The LCTA Secretariat has moved to new premises. Please update your records and use our new address for all future correspondence:

Lugano Commodity Trading Association (LCTA)

c/o
Fidinam SA
Secretariat
Via Maggio 1
6900 Lugano
Switzerland

Ph. +41 (0)91 973 14 21 (Ms. Barbara Falcetti)

Email info@lcta.ch

The Secretary General Monica Zurfluh can be reached by email at zurfluh@lcta.ch

On Friday November 24, 2023, at the Hotel Splendide Royal in Lugano, the Lugano Commodity Trading Association and Alma Impact AG held an event to discuss sustainability as a critical issue to the future of the Commodity Trading Sector. More precisely, to discuss the opportunities and the challenges that will arise in the coming years and the foreseeable impact on the demand and the operations, in the light of the “Carbon Border Adjustment Mechanism” law, a tax on imported carbon intensive products (cement, iron, steel, aluminium, fertilisers, electricity and hydrogen) recently introduced by European Union to avoid carbon leakage.

A heartfelt thanks goes to the speakers: Dominique Bruggmann from E&Y, Rumi Jahani from CarbonChain, and Simone Knobloch from Valcambi and to the moderator of the roundtable, the journalist Dimitri Loringett. This conference was also the last module of the ‘Certified Commodity Trading Specialist’ course recognized by the SAQ Swiss Association for Quality.

Press review

Materie prime, ecco la tassa UE per ridurre le emissioni (Corriere del Ticino – November 25, 2023)

CCTS program

Certified Commodity Trading Specialist (CCTS) – LCTA (2023 edition)

2024 dates and program to come soon.



The Commodity roundtable, organized by the Lugano Commodity Trading Association, took place on June 20, 2023. The event aimed to bring together professionals and experts in the commodity trading industry to discuss key trends, challenges, and opportunities in the market. The roundtable was followed by a networking apero, providing participants with an opportunity to connect and build relationships within the industry.

The Commodity Roundtable organised by the LCTA was attended by some 100 people at the magnificent Centro Studi Villa Negroni in Vezia/Lugano. The event witnessed a significant turnout, with a diverse mix of attendees including traders, brokers, analysts, industry experts, and representatives from various companies involved in commodity trading. It was an opportunity to take stock of the situation in different areas of commodity trading in Lugano thanks to the contribution of the various speakers Urbano Clerici (CEO, Coeclerici Compagnie SA), Renato Ginesi (CEO, GTrade System Suisse SA), Alberto Salsiccia (CFO, Petraco SA) and Norbert Stadler (CEO, DSS International SA). The panel discussion was masterfully coordinated by Roberto Grassi (CEO, Fidinam Group Holding SA).

The roundtable focused the attention on market trends and outlook. The roundtable discussion began with an analysis of current market trends in commodity trading. Spearkers shared insights on global supply and demand dynamics, price volatility, emerging markets, and regulatory changes affecting the industry. The discussions provided a comprehensive overview of the current state of commodity trading and potential future developments.

It was also a great opportunity to launch the new training programme organised by LCTA in cooperation with Alma Impact. The course called CERTIFIED COMMODITY TRADING SPECIALIST.

Following the roundtable discussion, participants had the opportunity to engage in a networking apero. The informal setting allowed attendees to connect, share experiences, and forge new business relationships. The networking session facilitated productive conversations and the exchange of contact information, fostering future collaborations and partnerships within the commodity trading community.

The first, entitled “Shipping and Logistic: Are we still sailing stormy waters?”; the moderator Michel’Angelo Piccinini (President, Propeller Club Port of Lugano) focused attention on the current dynamics of shipping after the difficult years of the pandemic, which have led to a limited supply of ships, an excessive increase in maritime freight rates, reduced activity of shipyards, and in general management difficulties related to covid19.



On 23-24 June 2022, after the forced hiatus due to the pandemic, the Global Commodities Conference 2022 took place at the LAC in Lugano (Lugano Arte e Cultura). This is an international event organised by the Lugano Commodity Trading Association (LCTA) and supported by the following sponsors: Allianz, Banca Stato, Chamber of Commerce of the Canton of Ticino, Coeclerici, EY, Flame, HFW, Propeller Club – Port of Lugano, Swiss Trading and Shipping Association (STSA), Ticino Welcome and Zug Commodities Association (ZCA).

The event, which was attended by more than 250 guests, confirmed itself as one of the leading industry meetings with the participation of international trade experts, commodity traders, banking institutions and various other service providers. It is important to note that due to the pandemic, it was decided to invite above all local speakers with ties to Swiss trading hubs.

At the opening evening on 23 June, LCTA Vice President Roberto Grassi interviewed the well-known journalist Antonio Caprarica. With a speech entitled ‘Commodity Trading – the challenging geopolitical landscape’, the special guest stimulated the audience’s interest by referring to his diverse and enriching experiences in journalism in various parts of the world.

On 24 June, on the other hand, the day was opened by Matthew Bryza, US Ambassador, who gave his views on the current geopolitical situation with a focus on the conflict in Ukraine.

The day was then divided into three parts.

The first, entitled “Shipping and Logistic: Are we still sailing stormy waters?”; the moderator Michel’Angelo Piccinini (President, Propeller Club Port of Lugano) focused attention on the current dynamics of shipping after the difficult years of the pandemic, which have led to a limited supply of ships, an excessive increase in maritime freight rates, reduced activity of shipyards, and in general management difficulties related to covid19.

Among the speakers were:

Harris Antoniou, Founder & Managing Director, Neptune Maritime Leasing Ltd

Gemma Carbone, Business Development Executive, Ifchor

Andrea Organista D’Amato, Principal & Chartering Manager, Armator Shipping

In the second, ‘Compliance and sustainability in war and resource shortage times’, the focus was on the current geopolitical situation in order to understand the functioning of various trading and financial activities in this complex and volatile environment characterised by international sanctions.

Speakers included:

Sarah Hunt, Partner, HFW

Taylor Konkin, Head of Commodity Trading Audit EY Geneva

Deia Markova, Head of Trade Commodity Finance, SGCIB

Thomas Patrick, CFO, DITH.

This panel was moderated by Pietro Poretti, Director Economic Development Division, City of Lugano, who captured the most relevant and interesting aspects.

Finally, with the third panel, entitled ‘Commodities shortage and global economy’, the conference took a more global slant on the supply of raw materials.

Speakers included:

Marco Arrighini, Head of Southern Region, Allianz Trade Switzerland

Matija Barudzija, CEO, ENET Energy SA

Marco Galimberti, CEO, DP Trade SA

James May, Director Strategy, DITH

The panel was expertly moderated by Florence Schurch, Secretary General, STSA

With around 250 participants over the two days and with several outstanding speakers and moderators, the event was stimulating and offered participants excellent opportunities to exchange, compare and network expertise.

Given the appreciation of GCC 2022, the organisers are already thinking about the next edition.

“Commodity Rountable” organized by LCTA took place on September 29, 2021, in Lugano.

President Matteo Somaini and Secretary General Marco Passalia gave a warm and enthusiastic welcome to all participants.

Great networking opportunity (with covid pass) during the apero and unique occasion to have a market overview from CEOs active in different commodity branches.

Also thank to the moderation of LCTA’s Vice President, Roberto Grassi, the event was dynamic and interesting. At the same time speakers were able to give real and pragmatic points of view about commodity markets. Our speakers were: Carlo Ghezzi, CEO, Gurta AG; Giovanni Marchelli, CEO, Coeclerici Compagnie SA; Vincenzo Romeo, CEO, Nova Marine Carriers SA; Murat Seitnepesov, CEO, Integral Petroleum SA; Norbert Stadler, CEO, DSS International SA.

During the evening there was also a very interesting presentation of Nathalie Morandini Siegrist, Special Projects Manager, EssentialTech Centre, EPFL.
Moreover, the photographer Marco d’Anna showed his artistic photos representing steel production and mining production.

On the occasion of the official visit to the City of Lugano of H.E. Wang Shihting, Ambassador of the People’s Republic of China in Switzerland, the President of the Lugano Commodity Trading Association (LCTA) Matteo Somaini had the opportunity to present the commodity trading sector active in Lugano, listing also the various commodities traded with China.

This exchange has made it possible to create long-lasting professional ties and important collaboration.