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Conflict Minerals

Conflict minerals” describes the complex of problems, that mining and trading in certain raw materials can help finance armed groups in conflict areas that are associated with serious violations of human rights, child labour and environmental pollution. The term is used mostly for the five raw materials tin, tantalum, tungsten, gold (“3TG” for short) and cobalt.

Tin and gold are used in the circuit board industry for the surface and cobalt (in small proportions) for connector gold / electroplated hard gold.

Important regulatory requirements for conflict minerals are currently:

  • OECD guidelines on due diligence in the supply chain
    global scope, initial focus on 3TG
  • US Dodd Frank Act, Section 1502 for companies listed on US stock exchanges
    "Conflict free" for 3TG with geographical limitation
  • EU regulation (EU) 2017/821 on due diligence
    global application for EU importers of affected raw materials (above quantity threshold)

Information on due diligence in the cobalt and mica supply chain is now also requested by some listed companies.

Multi Circuit Boards is not directly affected by the mentioned regulations.

However, these and other initiatives are still important to us. We carefully check our suppliers and also carry out regular examinations and updates. The Responsible Minerals Initiative (RMI, see below) reporting templates for conflict minerals (CMRT) and cobalt and mica (EMRT) serve as a basis.

Multi CB does not knowingly use metals from conflict regions based on the information provided to us by our suppliers.

On request we can send you our:
Conflict Minerals Reporting Template (RMI - CMRT) and Extended Minerals Reporting Template (RMI - EMRT)

Dodd-Frank Act - conflict minerals

The U.S. Dodd-Frank Act to reform the U.S. financial market law was signed in July 2010 by President Obama.

Section 1502 of the Dodd-Frank Act refers to conflict minerals from the Democratic Republic of Congo (and neighboring countries), and names explicitly coltan, tungsten, gold and tin, of which the latter two play a role in the production of circuit boards

U.S. companies listed at the stock exchange are obliged by Dodd-Frank to disclose whether conflict minerals are used in their products and if so, whether these minerals originate from the DRC or neighboring countries.

Responsible Minerals Initiative

The Responsible Minerals Initiative (RMI), formerly Conflict-Free Sourcing Initiative (CFSI), has become one of the most widely used and respected resources for companies dealing with responsible mineral sourcing in their supply chains.

A template can be downloaded from the RMI website that complies with the provisions of the Dodd-Frank Act and is designed to keep the supply chain manageable and free from conflict minerals. This template also includes a list of already certified smelters.

The RMI also offers itself to companies and their suppliers as an independent service provider who carries out the testing of smelters and refineries as "conflict-free", in accordance with current global standards.

ZVEI - position paper

The ZVEI (German Electrical and Electronic Manufacturers' Association), has recognized that the issue of conflict minerals intervenes deeply with the supply chain of German and European companies and thus it applies to the EU to prevent a law à la Dodd-Frank-Act.

The aim is to achieve a humanitarian solution that is viable for industry, e.g. the certification of the smelters as a "bottleneck". Certification extends to only a few companies and is traceable and verifiable. A chemical / geological proof of origin (fingerprint) of the raw materials is only possible before the smelting plant.

Certification of smelting companies is therefore easier to implement / verify than product-related certification across the entire supply chain and offers a significant added value as a system-safe approach.

Multi-CB supports the efforts of the ZVEI to enforce a mandatory registration of the smelters for suppliers of European companies.

Download: Position paper of the electrical industry on conflict materials, which reflects the problem and shows possible solutions.