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Get Ready for "Conflict Mineral" Compliance in the EU

Two years have passed since companies began reporting their use of so-called conflict minerals - tin, tungsten, tantalum, and gold - to the U.S. Securities and Exchange Commission (SEC) in accordance with rules adopted under the 2010 Dodd-Frank Act.

The rules, which continue to be the subject of a First Amendment challenge in the D.C. Circuit Court of Appeals, impose supply chain diligence requirements on SEC registrants relating to the sourcing of such minerals from mines and smelters that support militant groups in the Democratic Republic of Congo and adjoining countries (DRC Region). Since the rules apply to registrants that manufacture or outsource their manufacturing, a wide array of companies beyond their technology sector have been affected. These include companies in apparel and accessories (zippers, buckles, clasps, eyelets, and other fasteners), jewelry, toys, gaming machines, medical devices, lighting, home products, automotive, furniture, and other sectors.

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