How to Prepare for the New Conflict Minerals Reporting Requirements


ControlTek printed circuit board

Conflict Minerals Reporting

With the Federal deadline rapidly approaching, many companies are upping efforts to meet new Federal requirements for conflict mineral reporting as laid out by Section 1502 of the Dodd Frank Act.

As well-known companies like Intel come forward to report on their supply chains, many businesses now have proof that what seemed an insurmountable task is, in fact, quite possible with new processes and policies across the supply chain.

Here at ControlTek, we’ve been hard at work since the Dodd Act was enacted in 2010 to find a solution that could assist us with meeting these new reporting requirements.

ControlTek Conflict Minerals Policy

While not a publicly traded company, ControlTek manufactures products for companies that are public entities; therefore our efforts are to assist our customers in their own reporting efforts.

To help, we’ve put together the short guide below to help businesses on the road to a conflict free supply chain.

To view ControlTek’s response to conflict mineral reporting, click here.

Background on Conflict Minerals:

Like blood diamonds, conflict minerals are mined in areas of Africa that are currently involved in armed conflicts or human rights abuses. Unlike diamond jewelry, conflict minerals aren’t easy to spot for final products--tantalum, tin, tungsten and gold, are all minerals used in the manufacturing and assembly of printed circuit boards and electronics devices, which then go on to become finished products like cell phones, tablet computers and virtually any other electronic device on the market today.

The challenge for many manufacturers, then, is the multiple layers of supply chain that often exist between manufacturer and the mines themselves. It is because of this that supply chain partners at every level must combine their efforts if any manufacturer is to be able to eventually certify a conflict-free product.

Conflict Minerals Resources

Like most things in life, getting started is often the hardest step! Find resources below to help answer your questions and provide necessary information you will need for reporting.

Commonly asked Conflict Minerals Questions

What minerals are considered “conflict minerals”?

Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act

(the “Act”) defines “conflict minerals” as columbite-tantalite (tantalum), cassiterite (tin),Wolframite (tungsten), and gold.

What is the deadline for reporting?

Companies need to begin filing this with the SEC information starting in May 2014. They will need to disclose this information on their websites.

Who needs to report?

Companies are required to meet three criteria:

  1. The company must be publicly traded in the United States
  2. The company must manufacture or contract to manufacture articles
  3. The conflict minerals used in these articles must be necessary to the functionality or production of the article.

Other companies, like ControlTek, will file because we frequently work with companies which are publicly traded entities.

Finding Guidance:

There are several resources available to assist and to help you better understand the reporting requirements and prepare for for your own reporting.

SEC Conflict Minerals Disclosure - Understand What Must be Included

OECD Due Diligence Guidelines

Additional Information about Conflict Minerals and Reporting Template

We hope this information is helpful to our customers and any other businesses that need to prepare for the new requirements. While there is some possibility the legislation will be overturned before the May deadline, reducing the amount of conflict minerals in the electronics supply chain benefits all of us, and can only be done with the cooperation of our entire supply chain.

Get more information about ControlTek’s conflict minerals policy.

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