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Since the end of World War II, the commercial sector of the electronics industry has operated with comparatively
little influence due to geopolitical conflicts. Meaningful
shifts in international markets for electronic finished goods
most often derive from innovation or changes in countries’
international policies based on relatively peaceful coexistence, not combat.
The markets for certain source materials useful in
electronics component and assembly manufacturing,
however, are a different matter. In particular, four
elements—tin (Sn), tungsten (W), tantalum (Ta), and gold
(Au)—derive from mineral deposits found in, among other
places, the conflict zone in the eastern provinces of the
Democratic Republic of the Congo (DRC). Sales of these
materials, mined in and around the conflict region, have
helped finance armed groups, perpetuate regional violence
and human rights violations, and exploit area populations.
In an effort to make financing hostilities in central Africa
more difficult, the United States Congress passed the Dodd-Frank act in 2010 that, among many other things, added a
requirement for manufacturing companies that file certain
reports with the Securities and Exchange Commission
(SEC). Pursuant to section 1502 of the Dodd-Frank act, the
SEC issued its Conflict-Materials rule in August of 2012.
Subject companies must determine their sources of
tin, tungsten, tantalum, and gold—the so-called 3TG
elements—as being DRC conflict-free or not DRC conflict-free. Minerals are not conflict-free if mined in the DRC or
any of its surrounding covered countries (Angola, Burundi,
Central African Republic, Republic of Congo, Rwanda,
South Sudan, Tanzania, Uganda, and Zambia) unless a
diligent review of the mineral’s chain of custody determines
that the materials did not benefit armed groups. The SEC
required that reporting companies make their conflict-materials Form SD special disclosure reports public and
update them at least annually.
A sense of magnitude
A number of interesting things have happened since the SEC
rule issued. First, the additional scrutiny may have improved
the mineral mining reporting overall. For example, The
United States Department of the Interior US Geological
Survey (USGS) Mineral Commodity Summaries 2012
report does not show any of the covered countries as
meaningful providers of tungsten in 2010, the year Dodd-Frank passed but before the resulting SEC rule went into
effect. The 2015 Mineral Commodity Summaries indicate
that, by 2013, the reported tungsten output from covered
countries was 1,560 metric tons—a little less than 2% of the
worldwide annual yield.
It’s possible that mining concerns in the DRC and
Rwanda—the two covered countries producing the most
tungsten-bearing ore—entered the tungsten market during
by Joshua Israelsohn, Director, JAS Technical Media