In 2015, the European Union Parliament (“EU Parliament”) approved draft regulation imposing strict disclosure requirements on companies sourcing minerals from conflict zones. This regulation mirrors United States (“U.S.”) requirements set forth in Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd- Frank”).
According to the U.S. Securities and Exchange Commission (“SEC”) estimates, over 6,000 U.S. public companies are directly affected by the SEC Mineral Sourcing Rule, with cost estimates for initial compliance ranging from USD $3 billion to USD $4 billion. The impact in the EU of the Proposed EU Mineral Sourcing Regulation is anticipated to be significantly higher, with the EU Parliament’s estimate that over 880,000 European Union manufacturers will be affected by the EU’s proposed regulation.
Navigant’s new paper International Regulators Increasing Pressure on Companies to Eliminate Use of “Conflict Minerals” in their Supply Chains explains the significance of these global mandates and outlines several practical steps that companies can take to respond to the United States and European Union disclosure requirements.
 “Responsible sourcing of minerals originating in conflict-affected and high-risk areas.” Joint Communication to the European Parliament and the Council, Brussels, March 3, 2014. Pg. 6. http://trade.ec.europa.eu/doclib/docs/2014/march/tradoc_152228.pdf