Now in the third year of reporting under Section 1502 of Dodd Frank (US Conflict Minerals Law), there is speculation that cobalt may be added to the list of Conflict Minerals (3TG, Tin Tantalum, Tungsten, Gold) that require sourcing the chain of custody down to the mine to determine if mining the mineral supports violation of human rights.
The law includes open ended language allows Secretary of State to expand CMs and countries of interest, so if they want to add cobalt to the list of conflict minerals, they have that ability. Pushing for this addition are NGOs and human rights advocates who are concerned with cobalt mining in the Democratic Republic of Congo (DRC). A report from Amnesty International concludes that governments should include cobalt in their required due diligence and reporting on mineral supply chains.
Even if the government does not add cobalt to the 3TG list of conflict minerals, NGOs could pressure companies to include cobalt in their disclosures. The addition of cobalt to the list of 3TG could result in repeating source and chain of custody activities and due diligence of smelter by companies under the law.
For more information, please visit: http://www.conflictmineralslaw.com/2016/01/25/cobalt-and-conflict-minerals-3tg-and-c/