Sep 11, 2012 Wading through the U.S. Securities and Exchange Commission’s (SEC) 356-page final conflict minerals regulation poses its own share of challenges, not to mention all of the burden that compliance poses. To help electronics manufacturers and their suppliers make sense of the rule, IPC – Association Connecting Electronics Industries® has developed, “Summary of the Final SEC Rules on Conflict Minerals,” a 7-page document that is downloadable as a PDF file.
In response to IPC’s lobbying efforts, the SEC issued a more reasonable regulation but despite the improvement, the final rule may still be difficult to understand, let alone comply with. Continuing its leadership role in helping industry prepare for the costly regulation, IPC provides the summary as a free tool to help companies manage compliance.
Highlights of the summary include a simplified explanation of the compliance process: 1) A company must determine whether it is subject to conflict minerals requirements; 2) If yes, the company must conduct a reasonable country of origin inquiry to determine if the “necessary conflict minerals” used originated in the covered countries or are from recycled or scrap materials; and 3) If a company determines, or has reason to believe, that the conflict minerals originated in the covered countries and are not, or may not be, from recycled scrap sources, it must exercise due diligence on the source and chain of custody of conflict minerals and may need to provide a conflict minerals report (CMR).
Additional points include information on “phase-in” period implementation, audit standards and objectives, definitions of terms, conflict minerals report content and disclosure requirements.
IPC’s due diligence and data exchange committees will begin reviewing necessary changes to IPC-developed compliance tools and expect to publish a due diligence guideline document later this year. Said Joel Sherman, product environmental compliance manager, KEMET Electronics Corp. and co-chair of the E-30 Conflict Minerals Due Diligence Committee working on the guideline, “The document is intended to provide industry guidance within a flexible framework that companies may use to establish an effective conflict minerals due diligence program. We’re earnestly working to get the guideline out in November.”
To further help industry prepare for compliance, IPC will hold a series of conflict minerals seminars this fall.
To download “Summary of the Final SEC Rules on Conflict Minerals,” visit www.ipc.org/conflict-minerals-summary. For more information on IPC’s environmental policies and initiatives, contact Fern Abrams, IPC director of government relations and environmental policy, at FernAbrams@ipc.org or +1 703-522-2287.
IPC (www.IPC.org) is a global industry association based in Bannockburn, Ill., dedicated to the competitive excellence and financial success of its 3,100 member companies which represent all facets of the electronics industry, including design, printed board manufacturing, electronics assembly and test. As a member-driven organization and leading source for industry standards, training, market research and public policy advocacy, IPC supports programs to meet the needs of an estimated $2.02 trillion global electronics industry. IPC maintains additional offices in Taos, N.M.; Arlington, Va.; Stockholm, Sweden; Moscow, Russia; Bangalore, India; and Shanghai, Shenzhen and Beijing, China.
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