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Beveridge & Diamond’s 100 lawyers in seven U.S. offices focus on environmental and natural resource law, litigation and dispute resolution. We help clients around the world resolve critical environmental and sustainability issues relating to their products, facilities, and operations. 

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Showing 3 posts in Supply Chain.

New Developments and Uncertainties for Conflict Minerals Disclosure

The Securities and Exchange Commission (SEC or Commission) Division of Corporate Finance issued a new statement adding some uncertainty to company obligations and enforcement exposure under the SEC conflict minerals rule ahead of the May 31, 2017 filing deadline.  The statement is one of several moving pieces in an unprecedented wave of activity on conflict minerals in recent weeks.  Companies should review these developments and their approach to meeting legal obligations imposed by the SEC’s implementation of Section 1502 of Dodd Frank, alongside the broader expectations of customers, activists and investors. Read More ›

SEC Conflict Minerals Rule Faces New Scrutiny Ahead of May Filing Deadline

A flurry of activity on conflict minerals in recent weeks has added new uncertainty to the long-simmering debate over the future of U.S. conflict minerals reporting requirements. The U.S. Securities and Exchange Commission (SEC) announced plans to reconsider its 2012 rule implementing Section 1502 of the Dodd-Frank Act and requested public comments on all aspects of the rule.  President Donald Trump is reportedly considering a Presidential memorandum that could waive the SEC conflict minerals rule for up to two years based on national security interests. In what may be a step toward considering new approaches to addressing the responsible sourcing of minerals in the region, the State Department issued a broad request for stakeholder input to inform “recommendations.”  Read More ›

Highest EU Court: REACH SVHC Thresholds Apply at Component – Not Product – Level

In a break from European Commission and prevailing industry interpretations, the European Court of Justice (ECJ) held on September 10, 2015 that REACH concentration thresholds for substances of very high concern (SVHCs) that can trigger notification and communication requirements must be calculated at the component level.  For companies that had relied on the European Commission’s more favorable interpretation – calculating concentration thresholds for imported products at the product level – the implications of the court’s decision could be significant, perhaps necessitating an updated supply chain communication and compliance strategy for imports into the EU. Read More ›