NPI Services and T3G Conflict Minerals Compliance

The first reports for calendar year 2013 for compliance with the Conflict Minerals Law (AKA The Dodd-Frank Wall Street Reform and Consumer Protection Act) are due at the end of this month, May 31, 2014. Although a U.S. Appellate Court has recently ruled that a provision requiring companies to report publicly whether their products use conflict minerals violates the First Amendment, other provisions, including reporting to the Securities Exchange Commission (SEC), are still on track. Fortunately, NPI Services is also on track for its customers concerned with Conflict Minerals compliance.

While producing electronics free of lead and other specified hazardous materials (RoHS compliant) has become a familiar process, compliance with Dodd-Frank is quite another thing. Manufacturers may freely use tantalum, tin, tungsten, and gold, known collectively as T3G. However, publicly traded manufacturers of products using those minerals must conduct inquiry into their origin, and if the minerals are not from the Democratic Republic of Congo (DRC) or its neighboring nations, file a Specialized Disclosure (SD) with the SEC. If there is reason to believe the origin is indeed from the DRC or its neighbors, the manufacturer has an additional, and much more daunting process requiring due diligence to determine whether the ores from the conflict area come from mines that are funding conflict (which defines them as conflict minerals). The upshot is that manufacturers are highly motivated to avoid possible conflict T3G. Because conflict-area T3G represents a relatively small portion of the world supply of these minerals, avoidance of ores from the DRC area has not heavily impacted the supply of T3G. More recently, manufacturers have been able to produce conflict-free components, using minerals sourced from smelters that have been certified (a non-governmental initiative in response to Dodd-Frank) free of conflict mineral ores, including some ores mined within the conflict area. As the chokepoint in the supply chain for T3G, verifying at the smelter level has made it practical for electronic component manufacturers, jewelers, and others to produce certifiably conflict-free products.

The SEC reporting requirements apply to publicly traded manufacturers, but it behooves all those involved in PCB production to know whether the sources of all their components and materials are conflict mineral free. This applies not only to the component manufacturer and the company with the end product but to any party that has “actual influence” on the manufacture of the product, including assembly. At NPI Services, we meet your needs for component traceability, and we will continue to meet your needs with respect to RoHS and Conflict Minerals requirements. From MIL-PRF-55110 certified Printed Circuit Boards to ISO 13485 assemblies we have you covered! Call us and experience fast, efficient, personal service with the ease of doing business with just one PO!