“This may be the last time you have to hear about this,” consultant Lawrence Heim said of U.S. conflict minerals regulation. But even if legislation changes U.S. policy, customers – especially Europeans – will still require U.S. suppliers to meet compliance.

Speaking at the National Fastener Distributors Association and New England Fastener Distributors Association joint meeting in Boston, auditor Heim explained that the Trump administration is seeking regulatory roll-backs. The House of Representatives is in the “sausage making” stage of repealing Section 1502 of the Dodd-Frank Act.

Heim, of Elm Sustainability Partners LLC, has spoken to the NFDA on conflict minerals in the past.

Acting SEC chair Michael Piwowar has announced he is not going to enforce action 1502 and the SEC is considering amending existing rules.

Instead of a government regulation, it will be more a part of private contracts, Heim explained. Thus individual companies may still need to follow the rules if they do business with Europe.

The EU’s conflict minerals directive “impacts importers and smelters / refiners of 3TG into the EU,” Heim explained.  Supplier audits in the tin, tungsten and gold conflict minerals area will increase.

European companies “are terminating supplier relationships,” over conflict minerals issues, Heim noted.

“There is still a lot of sausage making to be done,” Heim said of congressional legislation.

The conflict minerals situation first affects the electronics industry.

What is a fastener supplier’s role in conflict minerals reporting? Heim said suppliers need to respond to information requests. Customers requesting information will have “increased expectations for validity, certainty and completeness.” 

Suppliers can “expect additional reviews or audits by customers,” Heim said. That can range from phone interviews to questionnaires to full audits.

“Company-level declarations will be less accepted” and customers will want information back to the parts level, Heim said.

Such information will include verification of smelter / refiner names, human rights abuses, human slavery and child labor issues.

“For now, continue as in previous years,” he advised. Be aware the issues can affect your customers or customers’ customers.

Thus far “nobody has a real solution” to the conflict minerals problems, Heim acknowledged. Web: nfda-fastener.org and nefda.com