Looking for Conflict-Free Smelters

One way to tell if your components include conflict materials is to make sure they come from a conflict-free smelter. The Solder Products Value Council (SPVC), a group within the IPC (Association Connecting Electronics Industries) is urging tin smelters to become smelters of conflict-free minerals through a new certification program.

Conflict materials include a number of minerals that are mined in the eastern Congo under brutal conditions. They include tin, tantalum, tungsten, and gold. These materials are used widely in consumer electronics. A provision (Section 1502) in the Dodd-Frank Wall Street Reform and Consumer Protection Act requires publicly traded companies to submit detailed reports to the Securities and Exchange Commission on the origin of the tin, tantalum, gold, or tungsten in their products.

The SPVC is recommending that smelters use the Electronic Industry Citizen Coalition/Global Sustainability Initiative (EICC/GESI) Conflict-Free Smelter (CFS) program. This audit and certification program will identify and publish lists of smelters that have been certified as using conflict-free minerals.

Karl Seelig, the SPVC chairman and vice president of technology at AIM Inc., urged smelters to participate. Tin smelters can help the entire electronics industry supply chain meet reporting requirements under the Dodd-Frank Act by engaging as soon as possible in a certification program, he said.

The CFS program will identify and publish lists of smelters that have been certified as using conflict-free minerals. "Although the regulations under Dodd-Frank have not been finalized, the CFS program is expected to benefit the entire supply chain by reducing the burden of compliance by identifying smelters of conflict-free minerals," Fran Abrams, IPC director of government relations and environmental policy, told Design News.

The SEC has not provided final regulations, but companies are getting ready for them. "A number of our members are acting proactively to prepare for compliance with the final regulations when they are issued," said Abrams. She noted that several IPC members are participating in a due diligence implementation project developed at the Organization for Economic Co-operation and Development. That project is a step toward avoiding conflict-associated minerals. "Other members are building supply-chain communications and internal tracking systems and developing due-diligence tools."

To help members with compliance, the IPC will post a link to the list of certified tantalum smelters on the EICC/GESI Website. "EICC/GESI plans to list tin, tungsten, and gold smelters in the future," said Abrams. She believes this smelter certification program might encourage smelters to pay attention to where their materials are coming from. "We hope that a significant number of smelters of conflict minerals will become conflict-free so that the manufacturers can easily select conflict-free materials."

The reporting requirements will apply only to publicly traded companies, but the IPC expects these requirements to rapidly flow through the entire supply chain. Companies not required to file reports with the SEC will probably need to provide similar information to customers that need to file with the SEC. The regulations will apply not only to US companies, but also to any company doing business or having customers doing business in the United States.