In August 2012, the U.S. Securities and Exchange Commission (SEC) finalized conflict minerals regulations that require publically traded companies to report the origin of tin, tantalum, tungsten and gold – conflict minerals – contained in their final products. Electronics manufacturing companies across the supply chain are impacted by this regulation. Even if companies are not publically traded, they will likely have customer requirements that must be met.
IPC has played an integral role in advocating for the least burdensome regulations. As a result of IPC's lobbying efforts, the final rule provides burden relief to the industry by establishing a unified reporting schedule, creating an indeterminate category, implementing a phase-in period, and removing the requirement that a CMR report is required for any recycled or scrap materials contained in a product.
The European Union is actively considering their own conflict minerals legislation. The current proposal sets up a voluntary self-certification scheme for firms exercising due diligence over commodity supply chain for gold, tin, tungsten, tantalum and their mineral ores. The voluntary self-certification scheme would require companies to exercise due diligence to demonstrate that their products' mineral components did not finance human rights abuses, and would offer incentives ranging from EU public procurement contracts to funding possibilities for small and medium-sized enterprises (SMEs). The proposed scheme will only apply to companies placing raw materials on the market – such as Europe's 20 or so smelters – and not importers of products.
IPC extensively lobbied the EU Commission, highlighting the difficulties experienced by companies attempting to comply with the U.S. SEC conflict minerals regulations. IPC supports the EU Commission's proposal because it would concentrate on "upstream" actors and avoid imposing an extra burden on industry.
IPC is actively engaged in advocating on behalf of our members. IPC has met with EU Commission officials and submitted extensive comments urging them to proceed cautiously before implementing conflict minerals legislation especially in light of the negative, unintended effects of Dodd-Frank. IPC will continue its advocacy efforts to promote conflict minerals legislation that avoids actions to unduly burdens manufacturing and commerce industries or cause unnecessary disruptions of the minerals trade.
Copyright@ 2007 MV Circuit Technology Co., Limited