|Days of miracle and wonder...|
If you manufacture gold jewelry and you have a wholesaler that directly supplies an SEC-listed company, you must talk to Acme and find out what they require, based on their communications with the SEC-listed company that is their customer. You'll likely need to obtain gold from LBMA “Good Delivery” sources or EEIC-GeSI “Conflict Free” smelters, or from other sources, such as banks, that are compliant with OECD due diligence guidance.
Compliance short-cut One way "around it" is to simply use recycled gold, or gold from existing stockpiles, if you are able to verify that representation. Here, you'll need careful inventory management to make sure supplies and products that conform to supply chain due diligence standards are separated from other sources.
Additional requirements can include the implementation of your own supply chain due diligence program, for example a program like this one can cut time and burden of supply chain communication and report generation, can hold certificates that your gold is conflict free, and can also keep records of independent third party audits. Legal resources include the Jewelers Vigilante Committee and Schulte Roth & Zabel.
Gold-plated compliance Yes, the Dodd Frank rules do not apply any minimum quantity to the materials involved. So if you supply gold-plated products — or products with metal alloys which contain tin, tungsten or tantalum, even in small amounts — you have to follow the appropriate procedures.
Sources outside the U.S. Even if you source gold jewelry from manufacturers and suppliers outside of the U.S., these suppliers have to provide you with assurances regarding their supplies. The EU is looking at some type of conflict mineral restriction in the next year-ish, so even if you weren't obligated you may as well get a leg up on an international obstacle course of conflict mineral rules. So yes, the rules apply to the supply chains of gold (and the other three minerals) irrespective of country of origin. If you source gold, tin or tungsten in any form—as components, settings, findings or finished products—your customer may well require you to get detailed information from your overseas suppliers about source.