Are you ready for Conflict Minerals Law?   

What it is: The Dodd-Frank Wall Street Reform and Consumer Protection Act, signed in to law on July 21, 2010, contains Section 1502 which refers to the use of Conflict Minerals in the Democratic Republic of the Congo (DRC). In short, this section is being referred to as the Conflict Minerals Law.  

Why it is important: Section 1502 is important to manufacturers and suppliers of electronics because it applies to minerals that are commonly used in electronics.    

What you need to know: The Conflict Minerals Law is not a ban on using certain minerals, however it contains new reporting and disclosure requirements for materials contained in products, as well as due diligence, audit and certification requirements.   

When you need to start: The SEC has delayed the publishing of the final rules to an estimated time frame of February 2012. Once the final rules are publshed, the rules have 60 days before coming into effect. Once the rules come into effect, companies need to comply by their full fiscal year thereafter. Even if your company is not required to report to the SEC, there is a strong possibility that if you manufacture or supply electronic products/components then you will have some obligation to provide information to a customer in your supply chain that does need to report to the SEC. Based on the essential use of identified minerals in electronic devices, it is anticipated that these requirements will be passed throughout the entire supply chain. While some details of obligations are still unclear (inability to determine material origin; definition of certification, etc.) companies should start tracking identified minerals now, so they will be ready to respond to requests throughout the supply chain.   

What are the Identified Minerals/Conflict Minerals (CM): The following minerals are identified as Conflict Minerals, known as the three “T”s and “G”:

1. Cassiterite (ore for tin): tin is used as solder on circuit boards in every electronic device we use
2. Columbite-tantalite (coltan, ore for tantalum): tantalum stores electricity and is essential to portable electronics and high-speed processing devices, such as laptops and cell phones
3. Wolframite (tungsten, wolfram, ore for cobalt): commonly used  in tools; enables cell phone vibration
4. Gold: used in the wiring of electronic devices
5. Or their derivatives and any other mineral, or its derivatives, as determined by the Secretary of State to be financing conflict in the Democratic Republic of the Congo or an adjoining country   

What you need to do: Track identified minerals in your supply chain; determine and disclose the country of origin of identified Conflict Minerals. This means determining the chain of custody
of the Conflict Minerals in your products and supply chain and disclosing your company’s sourcing practices of Conflict Minerals. If it is determined that you use Conflict Minerals, your goal should be to develop a “conflict free” supply chain in order to satisfy social demands, in addition to environmental requirements.   

How to do it: Using The GoodBye Chain Group’s (GCG) MDW-ES Product Environmental Compliance (PEC) software solution, your company can determine the material and substance composition of your products, including identifying Conflict Minerals. Once you know that your company is using minerals that may be identified as Conflict Minerals, you can satisfy requests throughout your supply chain regarding Conflict Minerals disclosure to your customers and begin efforts in determining the required chain of custody of Conflict Minerals. If you don’t already have MDW-ES, GCG can generate material and substance reports for you through our BoM Management Services including a Conflict Minerals report, that will identify minerals that may be determined as Conflict Minerals. Emerging legislation like the Conflict Minerals Law underscores the need for full disclosure data and material and substance management. GCG has been providing PEC software solutions using its award-winning MDW-ES software since 2003, when there were no tools yet available for substance and material data management. MDW-ES was the first software solution of its kind, and our experienced technical staff has over 8 years of experience managing all types of data and can provide you with any and all reporting needs relating to Product Environmental Compliance.  For more information on MDW-ES or GCG PEC Services, please email us at: This e-mail address is being protected from spam bots, you need JavaScript enabled to view it   or call 1-888-GBChain (1-888-422-4246) x 81.   

Why this law has been passed: For over a decade and a half, violent conflict has plagued the eastern Congo, causing more death than any war since World War II. Although the Congo’s conflict is long-standing, the Conflict Minerals trade remains the primary source.  Conflict Minerals are vital to the technologies that we use every day in electronic products making them worth hundreds of millions of dollars per year. The demand for Conflict Minerals provides incentives for the Congolese army to control strategic mines and trading routes using extreme methods of violence and exploitation, and has resulted in further violence growing from rebel groups, militias, and criminal networks.  Passing of this law hopes to accomplish some of the following: Developing industry-wide protocols for removing Conflict Minerals from supply chains resulting in “conflict free” supply chains; ensuring electronics companies pay more attention to the origin of the materials in their products and the social impacts of their material sourcing; limiting violence in the DRC by choking off revenue from rebel groups who commit violence and exploitation in the DRC over the Conflict Minerals trade; promoting a platform of transparency regarding Conflict Minerals and promotion of future supply chain transparencies; promoting “social” supply chain needs in addition to current environmental and safety needs in the supply chain.  

For more information: For more information on how GCG can help you comply with the Conflict Mineral Law, please email us at: This e-mail address is being protected from spam bots, you need JavaScript enabled to view it   or call 1-888-GBChain (1-888-422-4246) x 81.  

Resource Links:

Link to: Page 851   

IPC Link: H.R. 4173  

Enough Project: http://www.enoughproject.org

Make IT Fair:  http://makeitfair.org