The first reports for US conflict minerals reporting are due on May 31, 2014.   Although only companies that report to the SEC are officially impacted by the regulation, we’ve seen many other companies become impacted when they receive requests from customers for conflict minerals information.

The SEC’s conflict minerals rules require manufacturers to investigate and report on the origin of tin, tungsten, tantalum, and gold (3TG) in their products and whether or not the minerals came from a source that potentially funded conflict in the DRC.

As a first step, manufacturers are expected to perform a reasonable country of origin enquiry. Given that the mineral ores are acquired many levels up the supply chain, this is continuing to prove to be quite the challenge for most companies.

Many companies are expected to use the “indeterminate origin” category for the first couple years. However, the “reasonable country of origin enquiry” must be performed and all other requirements of the rules must be met (including SEC filing).

EICC/GeSI Version 3 template for 2014

EICC/GeSI are about to publish version 3 of their Conflict Minerals Reporting Template. Unfortunately, the template is not backwards compatible with the current version 2.03 template; therefore, EICC/GeSI is suggesting manufactures adopt the version 3 template for the 2014 calendar year purchasing of products, parts, and material that contain any of the 3TG metals.