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Conflict Minerals (US)


The Conflict Minerals Law and Your Business

The annual nature of the Conflict Minerals (Section 1502, Dodd-Frank Wall Street Reform Act) reporting process requires that each tier along the supply chain must continually improve its Conflict Minerals procedures in order to meet customer requirements for data collection and submission.

Need background?

Click here for basic information about Conflict Minerals (CM):

  • Requirements

  • Risks (Business, market, competitor, legal)

  • Solutions

Looking for Updates and Alerts? July, 2015: 3 recent Items of interest

1

What Happened

The two-year grace period for US publicly-traded companies to report their Conflict Minerals (CM) status as “Undetermined” ended, and these companies must identify 100% of their CM sources for CY2015.

What Impact It Might Have

Your customers may require 100% identification of your CM sources in order to meet their reporting obligations. Failure to do so may result in loss of business from these customers and from prospective customers.

What We Recommend

Begin collecting data from your supply chain immediately. Require 100% source identification from suppliers in order to meet this more stringent reporting requirement.

2

What Happened

The SEC made oral statements to the effect that CM contained in chemical compounds are outside the reporting scope. These statements have not yet been confirmed by a written policy or opinion letter from the SEC.

What Impact It Might Have

Determining whether to rely on these oral representations is a business risk decision which each company must make for itself. The final decision will affect the scope and magnitude of resources that will be required to collect CM data.

What We Recommend

Immediately explore your options at the appropriate management level. Make a formal decision in order to implement the appropriate data collection strategy in a timely manner. Strongly consider collecting CM data on chemical compounds, since you will also need that data to comply with REACH and similar regulations.

3

What Happened

An automotive client received a CM-related “corrective action” letter from one of its customers, requiring improved CM reporting in 2016 as a basis for contract renewals.

What Impact It Might Have

Failure to meet those “improved” reporting requirements would likely result in the loss of business from the client’s customer While speculative, it is likely that this supplier will receive similar “corrective action” letters in the near future

What We Recommend

Immediately allocate resources to improve CM data-collection. These resources will be amortized over data-collection activities for ELV, REACH and similar laws.