Dodd-Frank Act - Section 1502

Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 is a law passed by the US Congress and adopted on August 22, 2012. It details the reasoning for, and requirements associated with, the collection and reporting of conflict minerals (i.e., tin, tungsten, tantalum and gold, or ‘3TG’) used in manufacturing products in the United States. It also details what must be included in reporting information to the Securities and Exchange Commission (SEC). It established a due date for the reports to the SEC of May 31st each year.

*Note: There was a partial stay of one provision on April 14, 2014, as it was determined to violate the First Amendment by requiring companies to declare their products “conflict free.”

EU Legislation

The European Union (EU) passed a new regulation in May 2017 requiring companies producing or importing conflict minerals (i.e., tin, tungsten, tantalum and gold, or '3TG') to perform OECD due diligence to ensure they are importing from responsible sources and to identify conflict-afflicted high-risk (CAHRA) communities worldwide.

Conflict minerals can be used in products such as mobile phones, cars, other electronics, and jewelry. In politically unstable areas, armed groups often use forced labor to mine these minerals, using the proceeds to finance further exploitation, fuel other human rights abuses, and support corruption and money laundering.

AIAG is using best practices developed during the implementation of Section 1502 of the Dodd-Frank Act in the United States to assist companies in meeting requirements under this EU legislation.

  • The requirements applied as of January 1, 2021 for producers and importers of 3TG minerals and metals, with voluntary reporting by downstream producers of products containing 3TG. If there is inadequate downstream voluntary participation, the legislation contains provisions to convert to mandatory reporting for downstream mineral/metal users, potentially as soon as 2024.