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PMPA Issues Dodd-Frank Section 1502 Conflict Minerals Guidance

Tuesday March 19, 2013

PMPA staff has prepared a compliance guide based on our analysis and understanding of the SEC’s final rule.

Our guidance is based on our understanding of the logic and technology underlying the stated requirements in the final rule.

Our two page summary provides  a link to the final rule; an overview of the potential impact of the rule; explains the SEC’s determination as to what constitutes “Conflict Minerals” as applies to our shops; and clarifies the “necessary to production question” that concerns many people regarding scope of reporting being expanded to include conflict minerals used in our production machinery and tooling (it does not.)

In addition to identifying the focus minerals that are encountered in our industry, our report provides 5 questions to help you make sense of  and formulate your reply to each job and request for documentation from your customers for Conflict Mineral Status.

Finally, our document provides both the means to determine and suggested language to warrant that your product is “DRC Conflict Free” to your customer.

While not legal advice, our guidance identifies the critical characteristics that trigger the need for reporting, and how to identify if you have conflict minerals; and how report compliance to your customer in the absence of conflict minerals in your product.

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