Identify Your Sources of Conflict Minerals

As if we didn't have enough paperwork to support our day-to-day supply chain concerns, here comes another truck load of documents that may be worth their weight in gold.

I have been thinking about a possible company standard operating procedure for processing and reporting on conflict minerals (CM). In brief, according to the new government mandate, any public company whose products contain gold, tin, tungsten, or tantalum, will have to identify the smelter of origin of these minerals and file an annual report or face potential punitive damages.

So, rather than wait to the last minute (formal reporting begins in 2014) I looked at some of the existing resources to determine if it was reasonable to farm out such a task or handle the effort internally. I can't just ask the internal sales person who works at my electronics parts' distributor if anything I buy from them contains these minerals, but I can determine from material data sheets (MDS) a component's chemical composition down to parts per million.

So, if I can get an MDS for every part on my bill of materials (BOM) and visually or PDF search scan each document for the CM potentials, I can quickly create a pile of candidate parts that will require further due diligence.

My part master or item master data base should allow for including attachments to every part number. Typically, those attachments include such documents as drawings, specifications, product life cycle, PLM information such as product change notices or end-of-life alerts. Now, I need to start gathering the MDS documents for every approved part in my BOM. For that, I will need to contact every part's manufacturer and request the document.

Step one in this procedure is to identify the BOM of immediate interest. Step two is to use the manufacturer's contact information to email in a formal request for the MDS documents. You should have already created a table or form on which you track the OEM's responses by cross-referencing the part's MDS document to the part number. You will discover something rather quickly. Maybe 30 percent of your manufacturers have responded after two to three weeks.

The third step was to record the responses and the forth will be to follow-up with the remaining 70 percent of the slackers. So, let's say after a month or two, you have an MDS document for every part on the BOM. You have sorted through the MDS documents and determined that all of your semiconductors have tin on their leads and gold used for wire bonding.

Your bare-printed circuit card has gold fingers, and the solder used for attaching the electrodes onto your crystals contains tin as well. By the way, all of your tantalum capacitors, have tantalum. Now you are ready to move on.

Mail merge
Step five. You create a mail merge form letter to every one of the manufacturers referencing their part numbers, and in this letter you request an origin smelter report for the raw and processed CM minerals they have purchased from their suppliers. You ask them to specify the authorized smelter name and number. If they cannot do so, you are up a virtual creek without a mining pan.

This absentee return response either means they do not have the internal infrastructure in place to perform such supplier/smelter audit or they are in an information vacuum because they are buying from a supplier and that supplier's supplier is not able to or very slow in sourcing the required information.

You can refuse to do business with them in the future, remove the respective manufacturer's part number from your approved vendor list, and scramble for an alternate source that can produce a smelter reference. Or, you can hire an outside resource that will fill in all of the gaps in your BOM, letting you concentrate on that line-down situation in the factory because some bonehead didn't order enough sole-sourced parts for a build in progress.

14 comments on “Identify Your Sources of Conflict Minerals

  1. prabhakar_deosthali
    June 21, 2013


    You have shown a very clear-cut way to make that nasty due diligence of Conflict Minerals in a very systematic way and well in advance.  As always, the government requires a lot of paper work to be created to comply with every new regulation and it looks dirty work. Whether somebody reads this later is a big question ; but the process itself is a revelation for your company and will automatically create the awareness about how much environmentally sensitive minerals your products are using.



  2. ehcaneda
    June 21, 2013

    This is surely a dirty works for all SBMs and Component Engineering practitioners out there.

    Asking for Materials Data is such a pain in the a@$. It produces clattered documents and unstructure data. Not every data in Class 5 or 6 is helpful, I mean at least in my level of consciousness.

    I did this once with the RoHS exception 7 C (III) for chip capacitors where I asked for CoC and documents stating the companies implementation status of 7C(III). It did create confusion and hassle to both parties.

    Well, We did purchased IHS tool in which they do the work for us. They are the one doing the dirty work and presented to us an organized and easy to digest data for our use.

    My thought on this as an industry is we need to be mindful where we get the raw materials we used for our electronics parts. This includes the idea of Hazardous substances and its effect to our environment.The smuggling and blackmarket of getting this raw materials like what happen in Congo for Coltan (Columbite-tantalite) also adds up for the governments around the world to take this precaution and restrictions. 

  3. HarrisBo
    June 21, 2013

    Companies are becoming more aware of the harsh realities and real consequences of conflict minerals in their product supply chains. Understanding the countries of origin involved in a blurry smelting process can vary with great differences between materials and products involved. This makes tracking down the details of the required conflict minerals report for all companies who are producing products with the four main minerals.
    You must file a report if your company produces products or materials made with of the following types of minerals:
    These are some of the most critical components in Electronics, so these new procedures apply directly to many major manufacturers who we work with as electronics recycling partners in the Dallas, North Texas and US. Columbite-tantalite is used in capacitors and is critical in the production of speed combined with compact design and reliability oriented electronics like hearing aids and pacemakers. Cassiterite is critical for producing tin and is not just responsible for cans. The solder on a vast number of circuit boards is produced using Cassiterite as the main ingredient for its tin blend. Wolframite is the dense metal that makes many phones vibrate. Gold is used in so many applications from jewelry to electronics to dental products, even many companies that operate outside the country are finding out they'll have to report for gold related sales in the US.
    The reports are simple and the law carries many stipulations that exempt companies who have a legitimate issue with reporting. Despite the simplistic process and regulation, the laws impact has already been huge, cutting the trade of some of the guilty minerals by over 90%.
    Over the course of the drafting of the law many called for an exemption for recycling citing that it could help increase recycling efforts and lead to less need to mine around the world. An inquiry showed that reasonably only a small portion of recycled and scrap materials could be conclusively proven to be of offending origin, so the law outlined that: “If a company's conflict minerals are derived from recycled or scrap sources rather than from mined sources, the company's products containing such minerals are considered 'DRC conflict free.'”
    Regardless of the rulings BCD Electro has proudly worked alongside many other organizations for years to promote responsible trade laws and regulations that promote a fair global economy. BCD has helped companies with ethical electronic recycling of materials and downstream accountability showing that we keep a focus on promoting a healthy recycling environment. Some see compliance with the new law as a significant burden to their business, an unfortunate reality when some could have been using clean recycled components from right here in the US and instead chose the cheap African alternatives.
    BCD Electro
    BCD ( is a full service remarketing and recycling company. Through a broad suite of best practices, business-ready solutions, services and products BCD Electro provides secure and timely control of key product lifecycle management processes to help companies accelerate revenue, drive innovation, reduce costs, improve quality, and ensure regulatory compliance. We specialize in recycling IT , telecom, networking and hospital equipment as well as sales of excess inventory from manufacturing operations.

  4. dalexander
    June 21, 2013

    @Prabhakar…There is some additional value in CM records for the company and the CE in particular. Once you have all the component chemicals on file, you are able to assess the Waste Electronic and Electrical recycle/disposal requirement as well. With WEEE, the company has to anticipate take-back and recycle cost and also identify the processing players in advance of selling into the EU. So CM is like a preliminary identifier for actions to be taken that will help cover both CM and WEEE. At the rate we are destroying our environment, anything that helps delay the inevitable, can be considered a good thing or at least a positive move.

  5. dalexander
    June 21, 2013

    @ehcaneda… Yes, IHS is well equipped for managing CM data gathering and so is GreenSoft Technologies. They do all the REACH & RoHS regs too. Like any new process, there will be early bugs to iron out, and what will begin as a rough and tedious process, will be smoothed out and simplified over time. You would think Tantalum cap manufacturers would be the first out of the starting gate since their entire business is tantalum dependent. We should be looking for advanced press releases from KOA, AVX, and others that will establish them in their customer's eyes as being proactive and conscientious about CM matters.

  6. ahdand
    June 21, 2013

    @Douglas: Yes true, there will be bugs when you start using something new. From that only you will be able to identify how to improve the system. Without using you cannot figure out the bugs. 

  7. hash.era
    June 24, 2013

    @nimantha.d: Yes indeed, things will happen only after using it for some time. This will consume some time for sure but you cannot complain

  8. elctrnx_lyf
    June 24, 2013

    The governments regulation on conflict materials could give a chance to few new softwares that might help the OEMs to handle this correctly. Hopefully bigger manufacturers should announce their sources openly to avoid the time spent by various companies.

  9. hash.era
    June 27, 2013

    @electrnx: Why few softwares ?  

  10. ahdand
    June 28, 2013

    @Hash: I think that is because of integration issues. Anyway let him clarify it since he has experience on it.   

  11. hash.era
    June 30, 2013

    @nimantha: Integration issues ? Are you sure ?             

  12. hash.era
    June 30, 2013

    @electrnx: Yes you are right on track. What I feel is that the government should look into more positive factors and open the door for more vendors.                

  13. ahdand
    June 30, 2013

    @Hash: Just a thought but while reading the post I thought the main cause would be the integration issues.      

  14. Anand
    August 2, 2013

    The procedure of determining the presence of conflict minerals in products sold and distributed in commerce is complicated. Given the massive network of suppliers and distributors, supply chains can become an intricate web that grows tougher to manage the more complex a product is. Businesses may turn to consultants, but often the solutions they find are not scalable or reasonable, especially for large numbers of products and materials

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.