Adjoining Countries (Covered Countries)

Under U.S. Dodd-Frank Act Section 1502 and SEC Rule 13p-1, 'adjoining countries' are the nations that share a border with the Democratic Republic of the Congo (DRC) and are included in the definition of 'Covered Countries' subject to conflict minerals disclosure requirements. These countries are: Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.

Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502; SEC Rule 13p-1; Form SD, Item 1.01(d)(1).

SEC registrants must determine whether conflict minerals in their products originated in the DRC or any adjoining country. If the Reasonable Country of Origin Inquiry (RCOI) cannot rule out origin from any of these nine countries, the company must conduct full due diligence and file a Conflict Minerals Report. Supply chain data collection via CMRT must capture smelter-level country of origin data to make this determination.

A U.S. electronics manufacturer conducts an RCOI and determines that a tin smelter in its supply chain sources ore from Rwanda (an adjoining country). Since Rwanda is a Covered Country, the company cannot declare the mineral 'DRC conflict-free' without completing enhanced due diligence through a recognized audit program such as RMAP.