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IPC Comments to SEC on Conflict Metals

BANNOCKBURN, Ill. — Today, IPC — Association Connecting Electronics Industries® submitted comments to the U.S. Securities and Exchange Commission (SEC) regarding Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111-203, on the trade of conflict minerals. IPC supports the underlying goal of Section 1502, which is to prevent the human rights atrocities occurring in the Democratic Republic of the Congo (DRC).

The electronics industry, including IPC members, is actively involved in several initiatives to improve supply chain transparency in the conflict minerals trade. IPC, in its comments to the SEC, outlined in detail the complexities for the electronics manufacturer which include tracing conflict metals from finished products back through complicated supply chains to the smelter; tracing mineral ores from the smelter back to the mines of origin; and identifying which mines are conflict mines (mines whose output is controlled by or taxed by warring factions).

IPC encouraged the SEC to allow maximum time and flexibility for industry to implement the far-reaching rules of Section 1502 and allow companies the flexibility to develop appropriate, supply-chain-based due diligence processes. Attempts to fully implement the regulations without allowing time for solutions to be developed will cause unnecessary disruptions of the legitimate minerals trade which is vital to the livelihood of the people of the DRC. In addition, IPC encouraged the SEC to develop appropriate exemptions for recycled materials and materials already in the manufacturing supply chain at the time the regulations are implemented. IPC also encouraged the SEC to conduct a thorough economic analysis of the regulation before issuing a final rule.

“Unfortunately, the current lack of accurate information and the deficiency in the transparency associated with the tracking of conflict minerals complicates the situation,” says IPC President and CEO Denny McGuirk. “Without taking into account the current situation,” McGuirk warns, “the regulation could fall short of its underlying goal while having a substantial negative impact on the health of the U.S. economy, jobs, manufacturing, and exports.”

IPC’s recommendations ask the SEC to sharpen the regulation, target the requirements, and minimize the burden on legitimate trade.

For more information on IPC initiatives in the area of conflict minerals and to view IPC’s comments to the SEC, visit www.ipc.org/minerals.

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