Frequently Asked Questions
1) What is the Dodd Frank Act and how does it apply to lighting products?
The U.S. Securities and Exchange Commission (“SEC”) has adopted final rules implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. These rules impose disclosure and due diligence requirements on publicly-traded companies that manufacture products containing certain minerals designated as “conflict minerals” from regions associated with violations of human rights.
2) What are the minerals defined as “Conflict Minerals”?
Conflict Minerals consist of gold, columbite-tantalite (coltran), casiterite, wolfamite and their derivatives, tantalum, tin and tungsten, that have been mined or smelted in the Democratic Republic of Congo (the “DRC”) and adjoining countries. These minerals are commonly referred to as “3Ts and Gold”.
3) Where are the conflict regions?
The conflict regions include the Democratic Republic of Congo (the “DRC”) and the adjoining countries including the Republic of Congo, Angola, Burundi, Central African Republic, Rwanda, South Sudan, Tanzania, Uganda or Zambia.
4) Are any gold and 3T minerals considered “conflict free”?
Yes, minerals sourced outside the conflict regions – OR – validated as compliant with the Conflict-Free Smelter (CFS) program are considered conflict free.
5) What are the reporting requirements?
The SEC regulations require that publicly-traded manufacturers conduct due diligence and disclose the use of any conflict minerals used in their products on Form SD.