U.S. DFARS, Dodd-Frank, and Conflict Minerals Reporting

Question: The U.S. Defense Federal Acquisition Regulation Supplement (DFARS) prohibits the use of human trafficking and forced labor in the supply chains of contractors and subcontractors doing business with the U.S. Department of Defense. One part of the law stipulates that specialty metals must be melted in the U.S. or qualifying countries. If I am sourcing raw materials that are already DFARS compliant, do I still need to submit a Conflict Minerals Reporting Template (CMRT) to comply with Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act?

Answer: The CMRT asks that organizations take a reasonable approach to identifying materials and their sources of origin, meaning companies conduct due diligence on where the metal is mined, not just where it’s smelted. As such, DFARS compliance does not absolve companies from filing a CMRT.


This content is accurate as of May 10, 2019.

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