Conflict minerals

The reporting obligation lands on the company that files with the SEC, but the data lives deep in the supply chain. A connector carries tin in its solder, a capacitor contains tantalum, plating lines run gold. Tracing a finished part back to a mine is rarely feasible, so the industry standardizes on the smelter or refiner as the point of traceability: identify every smelter feeding your parts, then check each one against independent audit programs.

In practice, procurement runs an annual campaign built on the Conflict Minerals Reporting Template (CMRT): send it to every in-scope supplier, chase responses, and consolidate the smelter lists. Response quality varies. A company-level CMRT listing 300 smelters says little about your specific parts, so mature programs push for product-level declarations on high-risk commodities and anchor the obligation in the supplier code of conduct. Note what the law is not: Section 1502 does not ban DRC sourcing, it requires disclosure, and the EU runs a parallel regulation aimed at importers of the raw minerals. Most teams fold the CMRT campaign into their broader CSR and compliance outreach so suppliers answer one coordinated request instead of five separate ones.

Frequently asked questions

What are conflict minerals?

Conflict minerals are tin, tantalum, tungsten, and gold, collectively called 3TG, when sourced from the Democratic Republic of the Congo or adjoining countries, where mining has financed armed groups. The minerals appear in ordinary electronics: connectors carry tin in their solder, capacitors contain tantalum, and plating lines run gold.

What does Dodd-Frank Section 1502 require?

Under Section 1502 of the Dodd-Frank Act, SEC-reporting companies whose products contain necessary 3TG must inquire into the minerals' origin, perform due diligence, and disclose annually on Form SD. The law requires disclosure rather than banning DRC sourcing, and the EU runs a parallel regulation aimed at importers of the raw minerals.

How is conflict minerals traceability actually done?

Tracing a finished part back to a mine is rarely feasible, so the industry standardizes on the smelter or refiner as the point of traceability. Companies identify every smelter feeding their parts, then check each one against independent audit programs, escalating smelters that lack a conformant audit status for engagement or replacement.

What is the CMRT and how is it used?

The Conflict Minerals Reporting Template, or CMRT, is the standard questionnaire procurement sends to every in-scope supplier in an annual campaign, chasing responses and consolidating the smelter lists. Response quality varies: a company-level CMRT listing 300 smelters says little about specific parts, so mature programs push for product-level declarations on high-risk commodities.

How do you make a conflict minerals program manageable?

A conflict minerals program stays manageable when the obligation is anchored in the supplier code of conduct and the CMRT campaign is folded into broader CSR and compliance outreach, so suppliers answer one coordinated request instead of five separate ones. A typical cycle starts requests in January to meet the May 31 Form SD deadline, reaching response coverage in the range of 86% of suppliers.