CSS Industries, Inc.
Conflict Minerals Disclosure for the Year Ended December 31, 2016
May 31, 2017
As a public company, we are required under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Section 1502”), to provide certain information on our website if we determine that conflict minerals are necessary to the functionality or production of products manufactured by us or contracted to be manufactured by us. For purposes of Section 1502, conflict minerals are columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin and tungsten. Below we provide the information required to be provided under Section 1502 for the calendar year ended December 31, 2016.
Certain of our product lines consist of decorative containers (the “Containers”) made of tin-plated steel formed into a small box, which we may be deemed to contract to be manufactured. Certain Containers are for use as decorative packaging for gift cards, and other Containers are for use as storage boxes for recipe cards, prayer cards or other small items. Tin may be deemed necessary to the functionality or production of these products. Because tin is a “conflict mineral” as defined by Section 1502 of the Dodd Frank Wall Street Reform and Consumer Protection Act (“Section 1502”), we were required, under Section 1502, to conduct a reasonable country of origin inquiry with respect to the tin contained in the Containers made during the period covered by this report. Below we describe the reasonable country of origin inquiry that we performed, the results of such inquiry and our determination based on the results of such inquiry.
Conflict Minerals Disclosure
We source the Containers from unrelated, third-party manufacturers in China. The Containers are custom-manufactured to our specifications, which generally address the dimensions of the Containers and the names, logos and/or decorative designs that are printed on the Containers.
For purposes of our reasonable country of origin inquiry, we utilized a survey to collect information from the manufacturers as to the origin of the tin contained in the Containers. For the survey, we utilized the conflict minerals reporting template published by the Conflict Free Sourcing Initiative (“CFSI”) founded by members of the Electronic Industry Citizenship Initiative and the Global e-Sustainability Initiative.
The manufacturers advised us that the tin contained in the Containers was sourced from certain identified tin smelting facilities located in Japan and China. To ascertain the origin of the tin contained in the Containers, we consulted the resources available on the CFSI website. CFSI has developed a conflict-free smelters program, which CFSI describes as “a voluntary initiative in which an independent third party audits smelter procurement and processing activities and determines if the smelter showed sufficient documentation to demonstrate with reasonable confidence that their company processes minerals originating from conflict-free sources.” The CFSI website reflects that each of the aforementioned smelters is a participant in the conflict-free smelters program and that each meets the requirements for inclusion in CFSI’s list of conflict-free tin smelters, except that one smelter is listed on CFSI's "active smelters" list, which means that it is in the process of being audited by CFSI, according to the CFSI website. It was reported to us that the smelter on the CFSI "active" list has reported that it does not source tin from the the Democratic Republic of the Congo or an adjoining country.
Based on the reasonable country of origin inquiry described above, we have no reason to believe that the tin contained in the Containers for the period covered by this report may have originated in the Democratic Republic of the Congo or an adjoining country.