Yes this is an interesting topic Yes there has been no traceability in place even for ore going to Smelter. After Smelter all bets are off!!
Look how long it has taken to get system in place to obtain declarations from manufacturers/fabricators/suppliers of goods and materials for a company’s RoHS compliant product due diligence! Regards, Denis Ryskamp Product Environmental Compliance Trimble Dayton 5475 Kellenburger Road Dayton, Ohio 45424 (: 01-937-245-5539 -: [email protected] <mailto:[email protected]> P Please support the Environment by only printing this email if absolutely necessary. From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Thursday, October 21, 2010 11:59 AM To: [email protected] Cc: [email protected] Subject: Re: U.S. conflict-minerals law Brian, In the working group I participate in for this topic (and based on my on read of the section 1502) there is an effective "loop hole" for companies not publicly traded. This is perhaps due to the fact that it was put under SEC jurisdiction and they simply cannot impact non-public companies reporting (this is, after all, an SEC reporting issue, not a stop requirement). Your last question is the kicker, and I would add to it..., "how will a big company be able to trace its stuff to origin if the small component suppliers {that are not publicly traded in the US} do not have to indicate conformity" + and US publicly traded *distributors* {who might not be seen as producing anything} may also be out of scope + and all of the companies between the mines and the US boarders have no obligation to track or report the data (other than the contractual pressure that might be exerted by in-US-publicly-traded-producers)? You may know that the SEC is collecting public comment on while they work to develop the detailed regulations for the act. Reference http://www.sec.gov/spotlight/regreformcomments.shtml <http://www.sec.gov/spotlight/regreformcomments.shtml> Regards, -- Lauren Crane (mr.) Product Regulatory Analyst | Corporate Product EHS | Applied Materials Office 512.272.6540 | Mobile 512.736.7201 | America - Europe - Asia -external use- ** Save paper and trees! Please consider the environment before printing this e-mail. From: "Brian O'Connell" <[email protected]> To: <[email protected]> List-Post: [email protected] Date: 10/20/2010 07:25 PM Subject: U.S. conflict-minerals law Sent by: [email protected] ________________________________ Good People, YACR (Yet Another Conformity Requirement). A customer has asked if my employer will be able to make a declaration in accordance with the "Dodd Frank Wall Street Reform and Consumer Protection Act". My initial response was that there was no requirement because my employer is not traded on a major US stock exchange. Is this an actual 'hole' in the law, or did I not interpret correctly? How will a big company be able to trace its stuff to origin if the small component suppliers do not have to indicate conformity ? Brian - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc <http://www.ieeecommunities.org/emc-pstc> Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ <http://www.ieee-pses.org/> Instructions: http://listserv.ieee.org/request/user-guide.html <http://listserv.ieee.org/request/user-guide.html> List rules: http://www.ieee-pses.org/listrules.html <http://www.ieee-pses.org/listrules.html> For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]>
