PCB Fab and "Conflict Minerals" compliance.

[guscrown]

'm getting pushed by our legal department to start utilizing vendors that can confidently certify that they are NOT using raw material from the "Conflict Mines" in Congo. I use mainly two fab houses for all of our boards and one of them basically said they couldn't really determine where their raw material was coming from. The other at least said that they purchase all of their raw material from mainland China, but this is not so reassuring.

I'm basically looking for a US based fab house that can certify that they are NOT using "conflict minerals" in their process.

Some info on conflict minerals:

http://www.sourceintelligence.com/what-are-conflict-minerals/

[LabSpokane]

As for tantalum, I thought I heard Kemet supposedly purged their supply chain a while back.
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In fact Kemet guarantees conflict free tantalum. The rest of it is nearly impossible to fully verify. And I honestly believe that Kemet made a valiant effort to vet the tin, tungsten, and gold supply chains. Even they couldn't do it and many suppliers are reported as "undeterminable". 

[guscrown]

"Undeterminable" is what I am getting from my US based PCB Fab house, but this ain't cutting it for my company's legal department. I need to find a fab house that is actively eliminating conflict minerals from their supply chain.

[timofonic]

How this can be checked? There's tons of ways to lie about it if you apply some social engineering . If there isn't a way to check it scientifically, this is just marketing bullshit.

[mikeselectricstuff]

"Undeterminable" is what I am getting from my US based PCB Fab house, but this ain't cutting it for my company's legal department. I need to find a fab house that is actively eliminating conflict minerals from their supply chain.

..so tell them there isn't one. If they have a problem, they should tell the MD why all production has just stopped....

[guscrown]

"Undeterminable" is what I am getting from my US based PCB Fab house, but this ain't cutting it for my company's legal department. I need to find a fab house that is actively eliminating conflict minerals from their supply chain.

..so tell them there isn't one. If they have a problem, they should tell the MD why all production has just stopped....

Well, I found a few fab houses through google-fu that commit themselves to being "conflict mineral"-free, and I guess this would sit much better with our legal department, but I don't know these houses and I really don't know their quality.

http://www.sunstone.com/pcb-capabilities/environmental-sustainability

http://www.americancircuits.com/AboutUs/ConflictMinerals/tabid/78/Default.aspx

[LabSpokane]

"Undeterminable" is what I am getting from my US based PCB Fab house, but this ain't cutting it for my company's legal department. I need to find a fab house that is actively eliminating conflict minerals from their supply chain.

..so tell them there isn't one. If they have a problem, they should tell the MD why all production has just stopped....

Unfortunately, it's a law for *any* company traded on a US stock exchange.  I'd say the OP's legal department is really behind the power curve since the reporting deadline was 1 June. 

And none other than one of the world's toughest and most expensive law firms, Patton Boggs, is helping to litigate:  http://www.conflictmineralslaw.com/

A synopsis of the law:  http://www.sec.gov/News/Article/Detail/Article/1365171562058

[LukeW]

When you say the PCB fab house, are you only talking about PCBs without component assembly?

I doubt that the FR-4 and copper and soldermask etc has any conflict minerals going into it - however you're trying to provide paperwork for a lawyerocracy, so common sense doesn't apply 

Most of the world's tantalum actually comes from Western Australia. Congo provides almost none - something like 1% of global supply. The whole "conflict mineral" issue is overstated in the case of electronics, it's not that big a deal IMO. And different capacitor materials such as niobium oxide, polymers and better electroceramics generally mean we use less tantalum in EE today than we used to. It's probably more significant for "blood diamonds" than it is for tantalum.

[sleemanj]

When you say the PCB fab house, are you only talking about PCBs without component assembly?

I doubt that the FR-4 and copper and soldermask etc has any conflict minerals going into it -

Tin will be the problem i think.  Used during the plating process as a mask if i recall correctly.

[Tomorokoshi]

I'm basically looking for a US based fab house that can certify that they are NOT using "conflict minerals" in their process.

Here is another resource:
http://www.eiccoalition.org/

Are you specifying components by manufacturer part number in your BOM or are you letting the fab house decide based on parameters?

If they are deciding, can you get a list of actual part numbers before they go into production?

This web tool can provide conflict data:
http://www.siliconexpert.com/conflict-minerals-compliance-data

but it's very expensive to subscribe:
http://www.siliconexpert.com/products/part-search/pricing

I don't know what is out there as other resources that can look up that information by part number.

[mikeselectricstuff]

Could you not cover it simply by making compliance a condition of every purchase order or supply contract?