SEC's Proposed Rules on Conflict Minerals Disclosure Could Have Broad Impact

Cooley Alert
January 13, 2011

As required by the Dodd-Frank Wall Street Reform and Consumer Protection Act, the SEC has recently proposed a new set of public company disclosure rules regarding the use of "conflict minerals" from the Democratic Republic of the Congo (the DRC) and adjoining countries. The proposed new requirements are likely to impact a surprisingly large number of companies because conflict minerals are used in, or in the manufacture of, a wide variety of electronic products, including laptops, mobile phones, PDAs, DVD players, digital cameras, gaming devices and televisions. Conflict minerals may also be present in medical devices, airplanes, cars, machine tools, jewelry and a whole host of other products. The SEC has invited further comment on these proposed rules before they become final.

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