Materials Restrictions and Conflict Minerals
The presence of certain materials in products, and the human rights and mining practices associated with obtaining them, continue to be a major area of focus for legislators, customers and the public. Whether via regulations, standards or customer specifications, additional materials are constantly being evaluated for potential restrictions, and more scrutiny is being given to supply chain sourcing practices. Green Cognition has deep expertise on the policy implications and technical framework of these challenges and can advise clients on strategic business planning.
Highlights - Conflict Minerals
- Led ICT sector negotiations with Congress on the development of section 1502 of Dodd-Frank and testified to Congress (2013 and 2017).
- Led an ICT delegation to meet with each Commissioner of the U.S. Securities and Exchange Commission to secure a more favorable final conflict minerals rule provision regarding conflict minerals from recycled and scrap sources.
- Served as an invited industry expert (2012) at the European Commission Workshop on an "EU initiative on minerals originating from conflict areas" (2012); advised the EU on the development of its conflict minerals regulation and spoke at an EU event (2017).
- Served as the ICT sector spokesman with major television, radio and print media, including The Financial Times, The Wall Street Journal, CNN, The New York Times, BBC Radio and Time Magazine.
Highlights - Materials Restrictions
- Met with key Chinese officials in Beijing to discuss the implementation of China RoHS II and advocate for continued self-certification (2018).
- Testified to the U.S. Consumer Product Safety Commission regarding the "Petition Requesting Rulemaking on Products Containing Organohalogen Flame Retardants"; met with CPSC Commissioners to discuss the special requirements for electronics to prevent combustion (2017).
- Participated in the development of ICT sector Congressional testimony on TSCA reform (2013).
- Developed consensus ICT sector advocacy objectives related to the federal Consumer Product Safety Improvement Act (CPSIA); testified and/or advocated on RoHS and materials issues in California, New Jersey, Vermont and elsewhere.