Nearly 6,000 Companies Impacted by Conflict Minerals Law

According to the rule, an estimated 5,994 public companies that file with the SEC will have to provide new disclosures. Moreover, approximately 275,000 private companies that are part of issuers’ supply chains will also be expected to provide conflict minerals due diligence to their public customers. Furthermore, a 2011 study by Tulane University, assessed the costs of implementing the Dodd-Frank conflict minerals regulation to be $7.93 billion — more than one hundred times greater than the initial estimate prepared by the U.S. Securities and Exchange Commission (SEC) of $71.2 million that was later revised to $3 billion to $4 billion.

Companies are now discovering first hand that complying with the rule is not as straightforward as expected. Factor in the depth and complexity of global supply chains, language barriers, political obstacles, confidentiality concerns, supplier resistance plus the sensitive nature of the materials being traced and it is not surprising that over 75% of companies surveyed by PricewaterhouseCooper’s July 2013 report: “How Companies Are Preparing” are either inactive - waiting or unsure if the rule applies - or in the very early stages - beginning to identify products and suppliers of interest - of implementing their conflict minerals program.