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September 25, 2012

Lynn L. Bergeson, “Source of Minerals Gets New Scrutiny,” Chemical Processing, September 25, 2012.

Bergeson & Campbell, P.C.

On August 22, 2012, the Securities and Exchange Commission (SEC) adopted a final rule implementing Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. This important and sweeping rule is effective for products manufactured in 2013, and the first annual reports are due May 31, 2014, and on May 31 every year thereafter. It obligates companies using minerals that might have come from conflict zones to disclose their use. Because such minerals are utilized in catalysts or directly in production, the rule will impact many industrial sectors, including chemical manufacturing, electronics, paints and coatings, and automotive. Further, as the list of “conflict” minerals expands, others industries will be brought in under the scope of the rule.