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.