EU CMR and Dodd-Frank (U.S.) Conflict Mineral Regulation

The EU Conflict Minerals Regulation (EU CMR) is very similar to U.S conflict minerals legislation, particularly Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. However, the two are not identical.

One significant difference between the EU CMR and Section 1502 of the Dodd-Frank Act is that the EU regulation will apply to all conflict-affected and high-risk areas (CAHRAs) of the world, including the Democratic Republic of the Congo and Great Lakes Region, while the Dodd-Frank Act does not.

There are also additional differences in how the regulations address the due diligence process. However, global expectations on this issue seem to be converging. Moving forward, it seems likely that a common standard practice and set of expectations will emerge.

Article is current as of 2020-05-01.

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