February 2, 2017
Thank you for the opportunity to provide comments on the Conflict Minerals Rule. I am the managing owner of a small (4 employees including me, $490,000 revenue in 2016) contract manufacturing company that specializes in wire and cable harness assembly. Two of our employees are full time production the third is half production/half office activities I am responsible for all other supporting activities.
We provide our products and services to other OEMs that incorporate them into a bigger product - car, truck, crane, railroad, computer, etc.
On occasion (annually) from a couple of our customers, I am required to complete forms that advise that I am in compliance with the conflict minerals regulation. It can take more than an hour to wade through the paper work or figure out someone's web site where they want me to fill in the information on line. I buy parts from established distributors who buy from established manufacturers. Occasionally, these parts may have a plating or coating of a "conflict mineral" such as tin, lead or gold. These are standard parts that anyone can purchase on line from these established distributors. Their documentation shows that the parts may have the plating on them. Yet, I have to fill out pages of forms and try to find out what smelter they came from??
In the current form, this regulations costs me much time that I believe is wasted, as the manufacturers or even distributors are already providing more information on the parts than I have available to me Somehow, the regulation must be modified such that those of us further down the food chain would not be required to have to complete this information because it is redundant of the information being provided by at least 1 or 2 other layers of organizations above me.
Thanks for your time and consideration in reviewing this policy.