How to Efficiently Detect Conflict Minerals in Your Products
Many manufacturers are highly dependent on procuring raw minerals and metals to make the electronic parts within their products work properly. Let’s look at high-tech equipment such as smartphones, tablets, and cars as an example.
The components inside these products all contain minerals and metals such as tin, tungsten, tantalum, and gold (3TG). Unfortunately, the mining and trade of these raw minerals are often controlled by armed groups and subsequently help finance a vicious circle of conflicts.
The Democratic Republic of the Congo and the Great Lakes region in Central Africa are among the most obvious examples.
So, to keep manufacturers and their supply chain partners from sourcing raw materials from armed groups, legislation in both the US (Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Act of 2010) and the EU (The Conflict Minerals Regulation) requires manufacturers and suppliers to trace the origin of these minerals and metals.
That means companies who use conflict minerals, tin, tungsten, tantalum, or gold in their products need to survey their supply chain to gather information on the origin so they are able to report to relevant authorities.
It is important to note that it is not forbidden to obtain minerals and metals from the Democratic Republic of the Congo and the Great Lakes region in Central Africa, it is only certain smelters in that area, who are linked back to or known to finance armed groups.
It goes up and downstream
Responsibilities are clearly defined through the new regulatory framework for both “upstream” actors like mining companies, traders and smelters, and manufacturers who use these minerals and metals in the design and production of products and components - also called “downstream” companies.
But Slavko, how do I get my supplier’s information on potential conflict minerals?
I often get that question sent forward to me. So, I thought I would share a couple of best practice tips to help ease the process of declaring potential conflict minerals.
1) Remember to obtain certifications on procured raw materials
If your company is using any of these 3TG minerals, you will need to obtain information and certification of origin as part of the purchasing of the raw material from your supplier. Typically, you will want certifications from the supplier that declares the original source of the minerals and that it is not from armed groups.
The suppliers will have to provide a letter stating the name and location of the mine, foundry as well as the location and date of extraction, casting, etc.
You can start by sending a blank Conflict Minerals Reporting Template (CMRT) to all of your relevant suppliers with the request to fill it out. Typically, the template is passed down the supply chain to the point where it can be identified where the minerals are being refined and melted.
Once your suppliers send the completed template back to you, you will have all the information required to complete your own Conflict Minerals Reporting.
It is important to remember, the goal of a Conflict Minerals Reporting Template is to determine whether tin, tungsten, tantalum or gold is present in your parts/products, regardless of where they are sourced and in which parts/products the minerals are contained. That means you don’t have to wait for all your suppliers to get back to you before you create your own template, you can identify the percentage of feedback you have received.
2) Databases can be directly integrated with Minerva PLM
When the 3TG minerals information on a purchased component part and its electronics is documented, the next step is to gather further information in a component database. There are several component databases that can be utilized. One of these databases, IHS, is integrated within Minerva PLM, powered by Aras.
Minerva PLM streamlines your supply chain information with relevant component databases.
Simply go to the component inside Minerva PLM, and the platform will automatically retrieve the conflict mineral data along with other information like RoHS and REACH, etc. If the purchased part is not electronic or component you have to audit your supplier and ask for this information in a similar manner as in point 1.
As always, if you have any questions, do not hesitate to reach out to me.