Dodd-Frank Section 1502

Issuers whose products contain these minerals must conduct a reasonable country of origin inquiry and, where needed, due diligence following the OECD guidance, then file Form SD, with a Conflict Minerals Report where required, by May 31 each year for the prior calendar year. After a 2014 court ruling, issuers need not describe products as conflict free, and since April 2017 SEC staff guidance has limited enforcement of the detailed report.

Section 1502 reaches beyond listed companies because issuers push surveys down to suppliers, including contract manufacturers and private-label vendors. A brand selling electronics or jewelry to a public retailer will often be asked to complete the Conflict Minerals Reporting Template each spring, and 3PLs that offer kitting or light assembly may be asked too. Keeping smelter data from suppliers helps answer these requests and similar questions under the EU Conflict Minerals Regulation.

• Uyghur Forced Labor Prevention ActUFLPAUS law barring Xinjiang-made imports
• KittingAssembling several SKUs into one unit
• Country of OriginCountry where goods were made

• UK Modern Slavery Act 20152015 · UK law requiring slavery statements from large firms
• EU Forced Labour Regulation2024, applies from December 2027 · EU ban on products made with forced labour
• Corporate Sustainability Due Diligence Directive (CSDDD)2024, applies from 2029 · EU directive on corporate human rights due diligence

1. SEC: Conflict Minerals Disclosure final rule (2012) sec.gov
2. 15 U.S.C. 78m, Periodical and other reports law.cornell.edu