Key takeaway
What This Development Means
H.R. 7085 would repeal Exchange Act Section 13(p) and related Dodd-Frank provisions that underpin SEC conflict minerals disclosures. Even if enacted, many manufacturers may still face customer, investor, and non-US due diligence expectations for 3TG sourcing.
What would H.R. 7085 change for SEC conflict minerals disclosures?
The bill would repeal Exchange Act Section 13(p), the legal basis for SEC conflict minerals disclosure requirements linked to Dodd-Frank Section 1502. If enacted, US issuers would no longer be subject to that specific statutory disclosure obligation, although other contractual and regulatory expectations may remain.
Would conflict minerals due diligence stop if the SEC rule is repealed?
Not necessarily. Many companies would still be asked for 3TG sourcing data by customers and investors, and some supply chains are also influenced by non-US regimes and voluntary standards. Firms should assess contractual requirements, customer questionnaires, and any importer or downstream obligations that still apply to their products.
Source basis: US Congress, H.R. 7085 (introduced 15 January 2026)
H.R. 7085, introduced in the US House of Representatives on 15 January 2026, would repeal the statutory basis for the Securities and Exchange Commission (SEC) conflict minerals disclosure regime. The bill proposes deleting subsection (p) of Section 13 of the Securities Exchange Act of 1934 and making conforming amendments that remove Dodd-Frank Act Section 1502.
If enacted, the change would reduce a long running compliance obligation for certain US public companies, but it would not automatically remove supply chain transparency demands from customers, investors, and other jurisdictions.
What The Conflict Minerals Disclosure Rule Requires Today
The existing US framework is designed to increase transparency around minerals that may finance conflict in the Democratic Republic of the Congo and adjoining countries. In practice, it has driven supply chain information collection for so called 3TG minerals, tin, tantalum, tungsten, and gold, used in electronics, automotive components, industrial equipment, and aerospace applications.
Companies within scope typically conduct a reasonable country of origin inquiry, survey suppliers, and document due diligence processes. The disclosure obligation has also shaped supplier onboarding and purchasing conditions, because manufacturers often need upstream data to support their own reporting.
What Repeal Could Mean For Manufacturers And Suppliers
For issuers that currently manage conflict minerals programmes primarily to support SEC disclosures, repeal could mean fewer mandatory filings and less prescriptive public reporting. However, many supply chains treat conflict minerals information as a standard data request, particularly where end customers have their own governance rules or require evidence for responsible sourcing policies.
Businesses should also consider that conflict minerals expectations can be driven by more than the SEC. Customer contracts, lender requirements, and public commitments may still demand traceability, and non-US regulatory developments may influence what data is needed to access certain markets.
Summary
H.R. 7085 is a targeted repeal bill that would remove the Exchange Act provision underpinning SEC conflict minerals disclosure requirements. Compliance teams should monitor whether it advances through Congress, and in parallel review whether conflict minerals due diligence is still required by customers, investors, or market access conditions even if the SEC regime is rolled back.
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