Highlighted within the brief is IPC’s proposal for a three-year phase-in of the rules. IPC’s recommendations are based on the anticipated dates at which on-the-ground tracking systems, such as the ITRI bag-and-tag program, are in place and supplying verifiable conflict-free minerals. In addition, IPC believes the three-year period will give a significant number of smelters the opportunity to be audited and their products validated as “conflict free.” Without the phase-in, a de facto ban of minerals from the Democratic Republic of the Congo (DRC) and adjacent countries will be the only way to provide certifiably conflict-free minerals as there are no tracking systems in place.
White is a partner in WilmerHale’s Corporate and Bankruptcy and Financial Restructuring Practice Groups and is one of the firm’s leading practitioners in the area of corporate governance. White was recently featured in a Bloomberg News story on implementation of the conflict minerals provisions of the Dodd-Frank Act.
The brief is the latest initiative launched by IPC to advocate on behalf of its members that will be affected by the conflict minerals regulations. In February 2011, IPC conducted an extensive survey of its membership on the anticipated burdens imposed by the regulations. The study indicates that reporting requirements for conflict minerals would cost the electronic interconnect industry an estimated $279 million in the first year of implementation for due diligence alone, compared to the government’s estimate of $16.5 million.