by Jad Darsey
On August 22, 2012, the U.S. Securities and Exchange Commission (SEC) issued final rules for compliance with Section 1502 of the Dodd-Frank Act, and outlined what publicly traded companies in the U.S have to disclose regarding their use of conflict minerals in their products. The rule affects many industries including: High-tech, Appliances, Retail, Automotive, Aerospace, Manufacturing, Energy, Food, Medical devices, Jewelry and other consumer goods.
According to the rule, companies that utilize any of the 3TG (Tin, Tantalum, Tungsten, and Gold) minerals in their products need to conduct a reasonable 'country of origin' inquiry (RCOI) to determine whether any of the minerals originated in the covered countries or are from scrap or recycled sources and classify them as DRC Conflict Free, Not Been Found to Be "DRC Conflict Free" and DRC Conflict Undeterminable. There are specific program elements and reporting requirements for each classification.
More often than not packaging component decoration would be the cause for concern in our industry, but there is a possibility for these materials to come from other processes.
The latest announcement can be seen here: http://www.sec.gov/news/press/2012/2012-163.htm