IPC submits comments to SEC on conflict metals.November 24, 2010 -
IPC submitted comments to U.S. SEC regarding Section 1502 of Dodd-Frank Wall Street Reform and Consumer Protection Act, Public Law 111-203, on trade of conflict minerals. IPC supports goal of Section 1502, which is to prevent human rights atrocities occurring in Democratic Republic of the Congo. In comments, IPC outlined complexities for electronics manufacturers and encouraged SEC to allow maximum time for industry to implement rules and to develop supply-chain-based due diligence processes.
IPC Submits Comments to SEC on Conflict Metals
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IPC-Association Connecting Electronics Industries
3000 Lakeside Drive
Bannockburn, IL, 60015
Press release date: November 22, 2010
BANNOCKBURN, Ill., USA, - 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.
IPC (www.IPC.org) is a global trade association based in Bannockburn, Ill., dedicated to the competitive excellence and financial success of its 2,700 member companies which represent all facets of the electronics industry, including design, printed board manufacturing, electronics assembly and test. As a member-driven organization and leading source for industry standards, training, market research and public policy advocacy, IPC supports programs to meet the needs of an estimated $1.7 trillion global electronics industry. IPC maintains additional offices in Taos, N.M.; Arlington, Va.; Garden Grove, Calif.; Stockholm, Sweden; Moscow, Russia; Bangalore, India; and Shanghai, Shenzhen and Beijing, China.