Standards & Compliance

Conflict Minerals

Q: What is the difference between Dodd-Frank Section 1502 and the EU Conflict Minerals Regulation?

Dodd-Frank Section 1502 is a US disclosure law administered by the SEC. It requires publicly traded companies to determine whether 3TG in their products originated in the DRC or adjoining countries and, if so, to file a Conflict Minerals Report and conduct due diligence following the OECD framework. It is disclosure-based, not a ban. The EU Conflict Minerals Regulation (2017/821), in force since January 2021, instead places mandatory due-diligence obligations directly on EU importers of 3TG ores and metals above defined volume thresholds, and applies globally rather than only to the DRC region. A US RF manufacturer selling into Europe may face both regimes, so most reconcile them through a single Responsible Minerals Initiative process.

Q: How do I document conflict-minerals status for an RF subassembly?

The standard instrument is the Conflict Minerals Reporting Template (CMRT), an Excel workbook published by the Responsible Minerals Initiative and now standardized as IPC-1755. You roll up component-level declarations against your bill of materials, identify every 3TG-bearing part (tantalum capacitors, gold-plated connectors, SAC solder, tungsten carbide), collect each supplier's CMRT, and verify their named smelters against the RMI Conformant Smelter List. A part is reported as conflict-free when 100 percent of its smelters are RMAP-conformant. Smelter identification, not country of origin, is the unit of due diligence, because the smelter is the chokepoint where mixed ore streams converge and can be audited.

/KON-flikt MIN-er-uhlz/

Regulated under United States Dodd-Frank Wall Street Reform Act Section 1502, the term names four metals, tantalum, tin, tungsten, and gold (collectively 3TG), whose extraction in the Democratic Republic of the Congo and nine adjoining countries can finance armed groups. The reach into RF and microwave hardware is direct: tantalum sits inside solid electrolytic capacitors and thin-film resistor films, tin dominates lead-free SnAgCu solder governed by RoHS, tungsten appears in CuW heat-spreader carriers, and gold plates the contacts of nearly every connector. Public companies must trace these metals back through the supply chain to the smelter level and report their findings to the Securities and Exchange Commission, an obligation that runs in parallel with broader chemical-content rules such as REACH and export controls like ITAR.

Category: Standards & Compliance

Covered metals: 3TG (Ta, Sn, W, Au)

Primary law: Dodd-Frank §1502

Why 3TG Sourcing Reaches Into RF Hardware

Section 1502 of the 2010 Dodd-Frank Act directed the Securities and Exchange Commission to require disclosure when tantalum, tin, tungsten, or gold necessary to a product's function or production originates in the Democratic Republic of the Congo or an adjoining country. The rule is a transparency mechanism rather than an outright ban: a company that cannot certify a product as DRC-conflict-free is still permitted to ship it, but must file a Conflict Minerals Report describing the due diligence it performed. For an RF component maker the trigger is unavoidable, because tantalum capacitors, gold-plated SMA and 2.92 mm connectors, SAC305 reflow solder, and tungsten-copper amplifier carriers each contain at least one covered metal.

The investigation does not stop at the country of origin. The unit of accountability is the smelter or refiner, the point in the chain where ores from many mines are blended and where an independent audit can verify chain of custody. Roughly 300 to 320 active 3TG smelters worldwide are tracked by the Responsible Minerals Initiative, and a part counts as conformant only when every smelter feeding it has passed the Responsible Minerals Assurance Process audit. This is why an RF subassembly with a 200-line bill of materials can require declarations from dozens of suppliers before a single conformance statement is possible.

Due diligence follows the five-step OECD framework: establish strong management systems, identify and assess supply-chain risk, design a response strategy, support a third-party audit of smelters, and report annually. Most manufacturers operationalize this through the Responsible Minerals Initiative tooling rather than building a parallel process for each customer.

The OECD Five-Step Due-Diligence Framework

Smelter conformance ratio:
Conformance (%) ≈ (Conformant smelters ÷ Total identified smelters) × 100

BOM coverage of a declaration roll-up:
Coverage (%) = (3TG parts with valid CMRT ÷ Total 3TG parts in BOM) × 100

Reportable mass threshold (illustrative):
A single 47 μF tantalum capacitor holds ≈ 30–90 mg Ta; a gold flash of 0.5 μm over 25 mm² ≈ 0.24 mg Au

Where a product is reported DRC-conflict-free only when smelter conformance equals 100% across the covered BOM. CMRT = Conflict Minerals Reporting Template; 3TG = tantalum, tin, tungsten, gold.

The Four Covered Metals in RF Components

Metal	Source ore	Symbol	Typical RF use	Common substitute path
Tantalum	Columbite-tantalite (coltan)	Ta	Solid electrolytic capacitors, TaN thin-film resistors	MLCC / film alternatives, conformant smelters
Tin	Cassiterite	Sn	SnAgCu (SAC305) lead-free solder, plating	RMAP-conformant refiners
Tungsten	Wolframite / scheelite	W	CuW heat-spreader carriers, via fill	Recycled W, conformant smelters
Gold	Native gold ore	Au	Connector and bond-pad plating, wire bonds	LBMA / RMAP-conformant refiners

Common Questions

Frequently Asked Questions

Which four metals are classified as conflict minerals?

The rule covers tantalum, tin, tungsten, and gold, abbreviated 3TG. Each appears in RF hardware: tantalum in solid electrolytic capacitors and TaN thin-film resistors, tin as the base of SnAgCu (SAC305) solder, tungsten in CuW heat-spreader carriers and via fill, and gold in connector and bond-pad plating. Because nearly every RF assembly contains at least one, the rule reaches almost the entire microwave supply chain.

What is the difference between Dodd-Frank Section 1502 and the EU Conflict Minerals Regulation?

Section 1502 is a US SEC disclosure law: public companies must determine DRC-region origin and file a Conflict Minerals Report, but it imposes no ban. The EU Regulation 2017/821, in force since January 2021, instead places mandatory OECD due diligence directly on EU importers of 3TG above volume thresholds and applies globally. A US maker selling into Europe may face both, so most reconcile them through one Responsible Minerals Initiative process.

How do I document conflict-minerals status for an RF subassembly?

Use the Conflict Minerals Reporting Template (CMRT), standardized as IPC-1755. Roll up component declarations against the bill of materials, flag every 3TG-bearing part, collect each supplier's CMRT, and check their named smelters against the RMI Conformant Smelter List. A part is reported conflict-free only when 100% of its smelters are RMAP-conformant. The smelter, not the country, is the unit of due diligence because it is the auditable chokepoint where ore streams converge.

Related Terms

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