“Conflict minerals” (gold, tin, tantalum and tungsten) are necessary components in many manufactured goods. As part of the Dodd-Frank Act of 2010 Congress adopted a disclosure requirement which requires that companies who must file reports with the Securities and Exchange Commission (SEC) report on their use of “conflict minerals”. The requirements will also effectively force suppliers not subject to SEC reporting to maintain extensive records of their source materials, individually costing thousands of dollars to establish and maintain these records. The SEC is required to issue a regulation to implement this provision but has delayed publishing it until sometime between January and June 2012. The NAM currently estimates this SEC regulation could cost could manufacturers $9 to $16 billion to implement, while not achieving the intended objective.
The NAM is leading the business community’s efforts to ensure that the Security and Exchange Commission’s final rule on those minerals is pragmatic and not overly burdensome and costly.