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Largest Entity List expansion to date on 31 July 2026: 43 entities added, taking the list to 187, across aluminium, apparel, copper, cotton and tomatoes.
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The original supply chain disclosure statute, requiring conflict minerals reporting from SEC filers since 2014.
Calendar year 2025 filings fell due on 1 June 2026; the regime and the SEC enforcement posture are unchanged.
In plain language
Section 1502 requires SEC-reporting companies to determine whether their products contain tin, tantalum, tungsten or gold originating in the Democratic Republic of the Congo or adjoining countries, and to file conflict minerals reports describing their due diligence. The regime built the smelter-level audit infrastructure that later laws now rely upon.
Its lessons are studied as much as its text: a decade of filings shows both the possibilities of supply chain transparency and the limits of disclosure without consequences, a debate that continues to shape newer due diligence laws.
Obligations
Filers must conduct a good faith inquiry into whether covered minerals originated in the covered countries.
Where origin is covered or unknown, OECD-aligned due diligence and an annual Form SD filing are required.
Timeline
Dodd-Frank Act signed into law.
SEC adopted the implementing rule.
First conflict minerals reports filed.
Changelog
Reviewed after the 1 June 2026 filing deadline for calendar year 2025; no regime changes to report.
Annual review completed; no material regime changes.
Sources
Same jurisdiction
Largest Entity List expansion to date on 31 July 2026: 43 entities added, taking the list to 187, across aluminium, apparel, copper, cotton and tomatoes.
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