Like some of you, we have popped onto the SEC website to have a look-see at the recent Form SD filings from manufacturing companies such as Caterpillar Inc., as part of the first deadline for conflict minerals compliance. Any publicly traded manufacturing organization that uses (or may use) one or any of the 3TG (Tin, Tungsten, Tantalum and Gold) must file a Form SD.

FREE Download: The Monthly MMI® Report – covering Base Metal and Precious markets.

CORRECTED: As of today, SEC has received approximately 1315 forms

We recently caught up with Lawrence Heim, our resident expert on All Things Conflict Minerals and asked him to share with us some of his initial impressions based on his analysis of 110+ filings.

The Not-So-Surprising Observations:

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Last week, the European Union proposed conflict minerals legislation wildly different than what US manufacturers must currently comply with, calling for voluntary participation from importers only.

And yet the proposed EU legislation sees the pinch-point where it exists – at the smelter level.

“Focusing efforts at the root of the issue – material going into smelters and refiners – is a more efficient approach than the SEC’s ‘push from the top’ mandate,” said Lawrence Heim, Director of the Elm Consulting Group International, LLC and frequent contributor to MetalMiner.

The proposed European legislation incorporates the widely publicized and often discussed OECD conflict minerals framework. In some respects, the proposed legislation goes further than the SEC rules as the European legislation “applies to minerals sourced from conflict-affected and high-risk areas worldwide.”

In other words, the European legislation would go beyond the geographic boundaries of the SEC requirements or just the DRC region, according to Michael Littenberg of Schulte Roth and Zabel, who was also a recent speaker at MetalMiner’s Conflict Minerals EDGE conference held back in May 2013.

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conflict minerals compliance

Source: transatlanticacademy.org

In Apple Inc.’s latest Supplier Responsibility Report, they state that all of the company’s tantalum suppliers are conflict-free, using a third-party verification process.

Apple is also pushing their gold, tin and tungsten suppliers to use conflict-free material, according to this Times article, but those suppliers are harder for the company to muscle because Apple has less financial leverage with them.

Of course, Apple (along with HP, Nokia, Intel and others) has been at the forefront of conflict-free smelter sourcing due to their size and spots in the marketplace; but as we’ve reported over the last couple years, it’s much harder for smaller manufacturers to become compliant with the SEC’s conflict minerals law.

We thought it may behoove our readers to see the list of Apple’s suppliers and smelters – the company “identified that its suppliers use 20 global smelters or refiners whose tantalum has been verified by third-party auditors” as conflict-free, according to the Wall Street Journal – and see if you share any supplier or smelters in common.

Apple’s full list of suppliers.

Apple’s list of smelters.

If you do use any of these suppliers, and if you also source tantalum, can you be reasonably sure that these suppliers are providing conflict-free material? We encourage manufacturers to perform their own due diligence (we can help with that).

The compliance deadline for the Conflict Minerals Law is only a few months away – be ready!

Ok, we’d hoped that would catch your attention.

Before you accuse us of being male chauvinists (we are no such thing!), it doesn’t matter whether you’re a man or a woman – if you’re working for companies that source different metal products, all that matters is that you know how best to comply with the conflict minerals rule, inside and out.

Conflict Minerals conferenceSo with just ONE WEEK LEFT to register for our unprecedented one-day conference on the topic, here are a few questions you may have that we can answer:

Q:  Won’t this SEC Conflict Minerals Rule be overturned anyway? I thought the National Association for Manufacturers brought a winnable lawsuit against the SEC…

A: Don’t count on it, bub. While NAM has challenged the rule, chances are not good that the rule will be overturned. MetalMiner recommends that companies continue on the path of planning and developing implementation solutions, as many of the experts we have spoken to do not feel the legal case will actually change the reporting obligation on behalf of publicly traded companies.

Q: All right, my company doesn’t really have a Conflict Minerals compliance process yet…where the heck do I start?

A: Don’t worry, you’re not alone. However, do you have accurate records covering whom to contact (not only name and location, but also personal email and direct phone number information) for every supplier you have used over the past 18 months? Gathering that info may be a good place to start. Alternatively, if you only source a handful of parts, and you know they contain at least traces of tin, tungsten, tantalum or gold, you can undertake a part-centric approach.

Q: How can my company efficiently track this process and streamline my whole supply chain?

A: Thomas Kase, the lead analyst for our sister site Spend Matters, is all over it. One word: technology. More words – here’s what you have to look at, according to Thomas:

  • 3rd Party Enrichment – parent-child linkages, insights & validations
  • Contracts – what you have committed to on the sell-side
  • Customers – what you are about to commit to on the sell-side
  • Inform, Train, Document – across all areas, internal and external
  • Products – and components, sub-components and ingredients to gradually audit your way to the source (certify your entire supply chain, not just your suppliers)
  • Sourcing – early and full visibility to the sourcing process and team to enable early upstream correction
  • Suppliers (i.e, your vendors) – their locations, parents, and subsidiaries, which individuals to engage with at each level, etc.

At Conflict Minerals EDGE, Thomas will present how various players in the technology solutions sphere, “from ERPs to point solutions and modules from suite providers, can get the job done.” The MetalMiner and Spend Matters team will also address what you should consider doing at the same time as you roll out a Conflict Minerals compliance initiative.

Q: Can I still register??!?!?!

A: You bet. Click here.

Q: But what if I can’t make it to Chicago on May 6?

A: MetalMiner has the most comprehensive conflict minerals resource section for manufacturers. Look for the “Conflict Minerals” tab on the top right side of our site!

“Do you know you source conflict minerals (tin, tungsten, tantalum, gold)?”


“Do you know what you must do almost exactly one year from now?”


Yeah, these people aren’t ready either:

Source: IHS

That sample of electronics industry managers surveyed by IHS isn’t alone – in fact, if those in the electronics industry are behind, what does that say for the rest of us? Scary.

Here’s a follow-up poll, from EBN Network (a site covering the electronics industry supply chain):

Source: EBN Network

FULL DISCLOSURE: The one respondent who is “done and cracking the Champagne” – that’s me. I had to vote to see the results. (And I do always fancy myself cracking Champagne.) But in essence, not only is no one done; very few have even begun.

We at MetalMiner have known this for a while, and that’s exactly why we’re in the business of helping manufacturers become compliant.

How do we do that already? Check out our killer white-papers:

Need tangible tools, templates or solutions? Get them at our upcoming one-day conference:

Details and Registration

Conflict Minerals conference


Continued from Part One.

So while the degree of risk associated with the supply of each metal can be debated in broad terms, the layman can see how a country deprived of access to a ready supply of material would have problems maintaining a military the size of the United States’.

As an article in Proedgewire points out, President Obama’s fiscal year 2014 budget request includes $615 billion in military spending, but is largely silent on key strategic and critical material programs.

The US has operated a strategic reserve and a few metals such as tungsten, germanium and beryllium are said to be sufficiently covered by existing stockpiles to not be at risk, but others such as antimony, tantalum and bismuth would require significant stockpiles to safeguard supply.

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Last week, MetalMiner ran a story examining the import and export trends for tantalum. The author discussed the skyrocketing number of tantalum imports compared to falling US exports.

As a follow-up commentary to that guest post from our friends at Zepol, we’d argue the bigger story involves the month-to-month trends of imports (and not so much of exports) – and specifically the time period before and after the August 22, 2012, SEC conflict minerals rule promulgation.

According to Chris Grove, director of communications at Commerce Resources, a junior tantalum mining firm: “In Q1 2013, we became aware of a company in China that stopped selling material to the US…we understood that their feedstock did not comply with the conflict minerals rules.” In terms of the yearly import trends reported on MetalMiner, Grove said, “to be honest, the story’s trends make sense through the eighth month of 2012 (Ed. note: that Chinese imports increased), but this can’t be the story post-Aug. 22,” given the new rules.

“I would expect to see that pie graph shift quite significantly with China looking a lot different,” Grove suggested, “but the real question we have to ask is, has the country of origin changed along with the quantities?” Grove expects a significant drop in 2013 imports from China. If no data supports that then, “the tantalum industry has found a way around the ruling.”

And therein lies the rub.

RELATED: Do you source tantalum? Do you know how to comply with SEC Conflict Minerals rule? Check out Conflict Minerals EDGE.

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MetalMiner interviewed Jay Celorie, Global Program Manager at Hewlett-Packard and active participant in the EICC® (Electronic Industry Citizen Coalition) and GeSI® (Global e-Sustainability Initiative), regarding MetalMiner’s white paper, “The Definitive Guide to Conflict Minerals Compliance for Manufacturers.” Jay shared some of his thoughts on some of the key issues around conflict minerals, our paper and various approaches.

This portion of the interview continues from Part One, available here.

On Tin, Tungsten and Gold Supply Chains

“The electronics industry has been successful in recruiting many of the tantalum smelters to join the CFS Program. This was accomplished in part for many reasons.

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Neon-Alphabet_Study-O-Portable3TG, OECD, EICC, SEC, CFS, DRC…

Is this alphabet soup washing over you, scalding your skin, blinding your eyes?

We know how it feels. That’s why we’ve put together the definitive one-day conference for manufacturing professionals who source tin, tungsten, tantalum or gold-containing metals and materials – to answer all your conflict minerals compliance questions:


Taking place at the Hotel Sax in downtown Chicago, from 8:00 AM to 5:00 PM (CDT), this conference focuses on in-depth solutions, not just idle chatter and boring PowerPoint presentations.


Specific implementation tools, including

  • Checklists
  • Project plans
  • Templates
  • Technology maps and decision guides

Not to mention intimate discussions with the industry’s leading voices in conflict minerals compliance.


Download our recent free whitepapers:

Register NOW: Conflict Minerals EDGE

We recently caught up with Jay Celorie, Global Program Manager at Hewlett-Packard and active participant in the EICC® (Electronic Industry Citizen Coalition) and GeSI® (Global e-Sustainability Initiative), regarding MetalMiner’s white paper, “The Definitive Guide to Conflict Minerals Compliance for Manufacturers.” 

Intro: Sending an Economic Signal Toward Responsible Sourcing

A simple way to think about conflict minerals – and complying with SEC rules – is making sure that your economic signal is directed toward responsible sourcing. The EICC and GeSI organizations have provided a tool (the reporting Template) and a program (the CFS Program) to enable any company to accomplish this task.

From an industry perspective, we are focused on these efforts – the CFS Program, which validates conflict-free smelters, and the common reporting Template – a common data format to identify smelters in a company’s supply chain. Companies need to ask their suppliers to use these to identify their smelters and then ask those smelters to get on the CFS list.

If they are not on the CFS list, they must understand their customers may switch to smelters who are on the CFS list. Within the next few years, we expect to have a critical mass of CFS smelters and refiners for all four metals (tin, tungsten, tantalum and gold) that will enable electronics companies (at a minimum) to confirm they are sourcing conflict-free.

Below, Jay Celorie shared some of his thoughts on some of the key issues around conflict minerals, our paper and various approaches.

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