Printed circuit board fabrication and assembly relies on various metals for conduction, soldering, anti-corrosion, and other material properties that ensure high performance and reliability. The nature of these in-demand metals (not just exclusive to electronics manufacturing) makes them ripe for exploitation in some areas of the world. Many businesses have focused on internal and inter-organizational management methods to ensure conflict mineral use complies with local and international requirements. Conflict minerals reporting standards simplify the exchange of information between businesses, making it easier to stay on top of conflict mineral usage.
The Scope of Conflict Minerals Reporting
Conflict minerals reporting uses IPC-1755 guidelines to build the framework for exchanging conflict mineral data between suppliers, vendors, and manufacturers. Conflict mineral reporting focuses on 3TG – tin, tungsten, tantalum, and gold – as the basis for its investigation into material sourcing. While there are standards for data exchange that help provide the basis for reporting templates, businesses should understand that there is some wiggle room in how reporting occurs. Typically, conflict mineral reports will focus on seven key aspects:
1. Is Any 3TG Intentionally Added Or Used in Production Processes?
The first question cuts to the heart: is 3TG necessary for functionality or production? Due to prohibitive costs, it’s difficult to imagine that a manufacturer would add 3TG materials to production without good reason. Any raw materials, components, or additives used in manufacturing processes (including contracted work) are subject to evaluation.
| YES | NO |
|---|---|
| Tin-based solders | Tin found in bauxite |
| Tantalum capacitors | Trace tin in recycled steel |
| Gold or tungsten alloys | No 3TGs present |
Note that impurities in raw materials, components, or additives are outside the scope of the IPC-1755 conflict minerals reporting.
2. Is 3TG Present in the End Product(s)?
A follow-up question to the first requires examining the individual 3TG materials found. This question aims to identify the 3TG materials found that are unnecessary for functionality or production but may be present as residuals from the manufacturing process. As such, businesses should only answer “no” when 3TG materials are unnecessary in the manufacturing process or consumed in reaction as a catalyst.
| YES | NO |
|---|---|
| Tin used as a catalyst | Tungsten carbide blade/drill bit (no tungsten found in end product) |
| Tantalum welding rod | 3TG catalyst undetectable in end product |
3. Do Smelters Source 3TG from Covered Countries?
Covered countries at risk of 3TG conflict mineral sourcing include the Democratic Republic of Congo (DRC), Congo Republic, Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, and Angola. Businesses shouldn’t assume smelters source locally in countries with 3TG mineral reserves; if unable to confirm, an additional “unknown” option is available.
| YES | NO |
|---|---|
| Smelter indicates one of the above countries of origin | Smelter indicates a country of origin not listed above |
| Smelter publicly discloses they source from the region generally | Smelters source 100% recycled scrap |
4. Does 3TG Originate from Recycled Or Scrapped Sources?
A “yes” indicates all of the 3TG sourced is from recyclables or scrap metal, while a “no” means that at least some of the 3TG does not come from recyclable or scrap sources. An “unknown” option is available for smelters with unknown practices.
5. What Percentage of Suppliers Have Responded?
Managing 3TG conflict mineral reporting across multiple suppliers can be time-consuming. By identifying the number of suppliers in compliance with conflict mineral reporting, manufacturers can quantify a baseline of sourcing performance and establish year-over-year improvements as compliance rises.
6. Are All 3TG Suppliers Identified?
This question broadly assesses the overall compliance of the product supply chain: a “yes” indicates either a 100% response rate to question five or assurance of 3TG compliance based on publicly available information. In contrast, a “no” response indicates missing information from suppliers (this information may be on hold as the supplier responds).
7. Does the Report Contain All Response Information?
As a final check, conflicts mineral reporting uses an exhaustive declaration to ensure accurate reporting of all received information. There may be legitimate business reasons why response information remains unreported, but this generally requires an explanation.
Further Efforts to Proactively Source Conflict Minerals
Central to conflict minerals reporting is a continued commitment to due diligence in the supply chain that identifies areas of improvement. Beyond the immediate focus of 3TG materials, suppliers and other businesses should be able to answer the following adequately:
- Is there a conflict mineral sourcing policy in place?
- Is your conflict minerals sourcing policy available on your website?
- Is it a requirement for direct suppliers to be DRC conflict-free?
- Is it a requirement for direct suppliers to source 3TG materials from independently-audited smelters?
- What due diligence procedures are present for conflict-free sourcing?
- Do you conduct mineral surveys of your suppliers?
- Do you compare information from suppliers against internal conflict mineral sourcing expectations?
- Does the review process afford for corrective action management?
Your Contract Manufacturer Stays Ahead of Sourcing Challenges
Conflict minerals reporting requires significant effort from the manufacturer and supplier (as well as any other integral operations in the supply chain) to ensure safe and ethical sourcing of 3TG materials. While IPC-1755 provides an expansive framework, businesses can improve their internal tracking and commitment to the supply chain by implementing due diligence procedures that proactively prevent conflict mineral sourcing issues. While the work involved can be meticulous (especially for designers without experience), VSE is here to help. Our engineers are committed to building electronics for our customers, including a complete supply chain analysis. We’ve been building life-saving and life-changing products for over forty years with our valued manufacturing partners.
