Conflict Minerals Regulation more supply chain affecting than RoHS?
The Dodd-Frank Wall Street Reform Act enforced in 2010 requires regulated companies to report on the origin of so called conflict minerals as gold, tin, tantalum, and tungsten in their products. To trace the origins of these metals in their products, data and information has to be collected from the supply chain.
Regardless of whether the regulation directly applies to a company, there is an obligation to provide information on the presence of conflict minerals in the products offered. Compared to the RoHS Directive, conflict minerals compliance will be much more challenging because it will require knowledge not just of the substances in products marketed, but also of the origin of the metals themselves – in worst case back to the mining of the ore, but at least from the smelter.
Although this is a US regulation the European Union feels strong pressure to address conflict mineral as well in their regulatory activities – may be by end of the year already. How seriously will this impact companies producing in the EU and what are the measures to be taken immediately?
More detailed background information on the IPC space on Conflict Minerals
We have heard several options from companies how to address the conflict mineral regulation:
-the most elaborate and complex would be for a manufacturer to ask down the supply chain for every material/component for certificates, where the raw material is coming from
-most of these requests would end at some few smelters, so an alternative approach would be to have certified smelters, who confirm that they do not use conflict minerals
-the exclusion of conflict minerals could be done on the level of a supplier contract, which would require updating all supplier contracts
-the simplest way of dealing with the challenge could be to include a paragraph in the code of conduct of a company that requires all suppliers not to deal with conflict minerals