Dodd-Frank §1502
Dodd-Frank Act §1502 (Exchange Act §13(p)) — Conflict Minerals; SEC Rule 13p-1 and Form SD
Topic : Supply chain due diligence · Level : National
Today
Form SD still due yearly (CY2025 due 1 Jun 2026). Repeal bill H.R. 7085 reported (H. Rept. 119-560, 19 Mar 2026); no floor vote.
Summary
US-listed companies must check whether tin, tantalum, tungsten or gold in their products come from the DRC or neighbouring countries and file Form SD each year. A House bill to repeal the rule passed committee in January 2026.
Who is concerned
- Turnover
- non précisé
- Employees
- non précisé
- Listed company
- cotées seulement
- Sectors
- Electronics
- Automotive
- Industrial equipment
- Jewelry
- Triggering activities
- SEC reporting issuer
- 3TG needed in a manufactured product
- Extraterritorial reach
- Yes
Issuers survey suppliers worldwide, typically via the RMI CMRT, to trace 3TG to smelters and origin.
- Examples
- US electronics maker
- Foreign private issuer in auto parts
- US medical device company
What the law requires
- Conduct a reasonable country-of-origin inquiry on 3TG in products
- File Form SD with the SEC by 31 May each year
- Publish the disclosure on the company website
Penalties
No specific fine; SEC enforcement under the Exchange Act. Staff will not recommend action on Conflict Minerals Report (Item 1.01(c)).
What this changes for a supplier in China
Chinese component makers receive yearly CMRT requests naming the smelters and refiners for tin, tantalum, tungsten and gold used in parts.
Expected evidence
- Completed RMI CMRT template
- Smelter list with RMAP status
- Sub-supplier declarations for 3TG
Tiers : Tier 1-N