SEC Rules and Frequently Asked Questions

Legal Guidance

  • RILA Legal Analysis - Released by RILA, and intended to provide retail companies with (1) a summary of the SEC's 3-step analysis and (2) guidance for retailers to understand the critical phrases "contract to manufacture" and "necessary to functionality or production" as used by the SEC in the final rule.
  • AAFA Legal Guidance - Released by American Apparel & Footwear Association, and intended to be used in conjunction with the final rule.

Supply Chain Reporting & Due Diligence

  • CFSI Reporting Template - Reporting template for retailers to query their supply chains.
  • OECD Due Diligence Guidance - Guidance related to the "due diligence" reporting requirement in the SEC rule. See in particular the 5 step process; red flag triggers; Annex II: model company policy.

Other Useful Resources

  • Conflict Free Sourcing Initiative (CFSI) - Resource from the Electronic Industry Citizenship Coalition (EICC) and the Global e-Sustainability Initiative (GeSI) to provide information and tools. Includes the Reporting Template, an overview of conflict minerals, the situation in the Democratic Republic of the Congo, and various reporting and 3TG sourcing resources.