Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act requires SEC-reporting companies to disclose whether their products contain conflict minerals (3TG: tin, tantalum, tungsten, gold) that originated in the Democratic Republic of Congo or adjoining countries. Like the EU Conflict Minerals Regulation, cobalt is not currently within the formal scope of Section 1502, but the DRC's dominance in cobalt production creates significant practical overlap.
Disclosure Requirements
Companies subject to Section 1502 must file a Conflict Minerals Report (Form SD) with the SEC annually if conflict minerals are necessary to the functionality or production of their products. The report must describe the due diligence measures taken, the results of those measures, and whether the company has determined that its products are "DRC conflict free."
Cobalt and the DRC Nexus
While cobalt is not a 3TG mineral, companies that manufacture batteries, EVs, or electronics containing cobalt from the DRC face reputational and regulatory pressure equivalent to Section 1502 obligations. Many companies voluntarily apply Section 1502-equivalent due diligence to cobalt, using the Responsible Minerals Initiative's Cobalt Reporting Template (CRT) alongside the standard Conflict Minerals Reporting Template (CMRT).
CMRT and CRT Reporting
The RMI's Conflict Minerals Reporting Template (CMRT) and Cobalt Reporting Template (CRT) are the industry-standard tools for collecting supply chain information from suppliers. The CRT specifically covers cobalt sourcing, refiner identification, and due diligence status, enabling companies to identify CoRAP-conformant refiners in their supply chains.