Do your products contain conflict minerals?

Published: 12th August 2011
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Environmental compliance does not only cover RoHS, REACH and WEEE issues. It also has a humanitarian focus. Recently, new legislation was passed in the US Senate which has profound ramifications for the electronic engineering industry, concerning materials widely used in electronic and mechanical design.



The new legislation concerns section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, as implemented by the US Securities and Exchange Commission (SEC). This demands that any company listed on the US stock exchange, which uses Conflict Minerals in manufacture or production, must disclose if they originate from the DRC Zone countries. If the conflict minerals originated from outside the DRC Zone, the Annual Report should show evidence of how this was determined. In the event the minerals originated from within the Zone, a separate report must be provided to show due diligence was exercised regarding the material source and supply chain. The Act does not seek to ban the use of these minerals (unlike other types of environmental compliance legislation, such as RoHS and REACH), but to ensure profits from trading do not fall into the wrong hands.



The term Conflict Minerals refers to four products mined in the DRC Zone, an area of hostile conflict with an appalling record of human rights abuses. The area comprises the Democratic Republic of the Congo, and the countries sharing its border, i.e. Angola, Burundi, Rwanda, Sudan, Tanzania, Uganda, Zambia and the Central African Republic. Around seven million civilians are believed to have died there since the atrocities began, many of them children.



The Conflict Minerals have a particular relevance to PCB designers and mechanical engineering companies. They comprise:



Columbite-tantalite (coltan), the metal ore from which tantalum and niobium are derived. Tantalum is widely used in electronic technology, for example mobile phones, digital cameras and computers, as well as the manufacture of jet engine components and carbide tools. Niobium is widely used in gas pipelines, aerospace engines, superconducting magnets, electronics and optical components.



The metal ore Cassiterite, most commonly associated with the production of tin. It is an important component of leaded and lead-free solders.



Wolframite, the metal ore from which tungsten is derived. Tungsten is widely used for electrodes, wires and metal contacts in electronic and electrical applications. It is also used in lighting and welding.



Finally, gold is widely used in communications and aerospace technology, being prized for its superior conductivity and resistance to corrosion.



This list is not exhaustive, and includes derivatives of the above compounds. The Secretary of State reserves the right to include any other mineral not listed, if he feels the proceeds are financing the DRC Zone conflict. Naturally, no engineering company in the US wants to be associated with the atrocities taking place in Africa, but there are concerns among OEMs as to how the new legislation will affect costs and impact on the supply chain and foundry production. With so many electronic and mechanical engineering components being outsourced, establishing a "chain of custody” from source to vendor is an uphill task.



We at Enventure Technologies offer a comprehensive range of environmental compliance services, and are one of the few companies covering Conflict Minerals legislation.



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