Conflict Minerals & Dodd-Franck Act Section 1502

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What are conflict minerals and the Dodd-Franck Wall Street Reform and Consumer Protection Act?

The Dodd Frank Act Section 1502, part of the U.S. government’s Dodd-Frank Wall Street Reform and consumer Protection Act, signed into law in July 2010, requires publicly traded companies to ensure that the raw materials they use to make their products are not tied to the conflict in Congo, by tracing and auditing their mineral supply chains.

The Dodd–Frank Act Section 1502 is intended to make transparent the financial interests that support armed groups in the DRC area. By requiring companies using conflict minerals in their products to disclose the source of such minerals, the law is aimed at dissuading companies from continuing to engage in trade that supports regional conflicts.

In August 2012, the Securities and Exchange Commission (SEC) issued its Conflict Minerals Rule along with guidance for how companies should report on the source of the conflict minerals in question: tin, tungsten, tantalum, and gold also referred to as 3TG.

These so-called “conflict minerals” can be used in everyday products such as mobile phones and cars or in jewelry.

All US companies must collect conflict minerals information from suppliers with the assistance of Assent Compliance.

In Europe, the EU regulation aims to:

  • ensure that EU importers of 3TG meet international responsible sourcing standards,
    set by the Organization for Economic Co-operation and Development (OECD)
  • ensure that global and EU smelters and refiners of 3TG source responsibly.
  • help break the link between conflict and the illegal exploitation of minerals; and help
    put an end to the exploitation and abuse of local communities, including mine workers,
    and support local development.

The regulation requires EU companies in the supply chain to ensure they import these minerals and metals from responsible and conflict-free sources only.

The requirements for EU importers apply from 1 January 2021.

So, all companies in US may ask for “conflict minerals” declaration from Trelleborg under the The Dodd Frank Act Section 1502 and from 2021 all European based companies may ask for the same.

Trelleborg has developed a Recommendation on Conflict Minerals (including all supporting documents) to provide general information on the Dodd-Frank Act, Conflict Minerals reporting requirements and to provide various tools to respond to customer requests or conduct downstream due diligence with your own suppliers.

To get the official Trelleborg statement to send to customer, please contact our Quality Department at Clermont-Ferrand who will provide you the Trelleborg letter signed by Gérald Soulagnet.

Contact our Expert

Gérald Soulagnet

GSO