largersmall2016/12/28 11:05:58
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.
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