The only activity of my company is industrial painting; we paint the parts provided by our customer and return them painted. Do we really need to concern ourselves with conflicts minerals compliance?
Generally, under the United States Dodd Frank section 1502 conflict minerals law, the application of paint to another party's product would be deemed a service.
If the part is provided by the customer and your company’s role is exclusively to apply paint, the in-scope portion of your declaration is either:
- The paint itself, assuming you are the manufacturer of the paint and the paint contains 3TG
- Nothing, provided you are not the manufacturer of the paint and your company’s role is exclusively in the application of a third party paint selected by the customer onto the customer's part
If however, your company is purchasing the part from a third party, then finishing (painting) the part and branding the part as a product marketed by your company, then your company would be responsible for performing the due diligence and making the associated declarations.
**Article contents valid as of 2017-08-03