Before the conflict-minerals regulation was enacted, what kinds of materials monitoring was Brooks doing?
We’ve been heavily involved with it for the last few years. We have engineers here in the United States as well as our engineering team in China that continue to monitor all our products. As we roll into 2014, the conflict-materials rule is adding to the list of more and more things that we will continue to test.
What do you test for now?
We already test our kids’ shoes, making sure that there’s no lead in them. The conflict-minerals rule has really taken [testing] to another level because it’s getting more and more of our supply-chain partners involved. That’s because we really need to understand where they are purchasing raw materials. In the past, we’ve done materials testing to make sure that our products do not have certain materials. We really weren’t concerned about the source.
How many of your products will it affect?
It’s a small issue for us, relatively speaking, because — especially on the footwear side — we don’t use a lot of the materials listed as conflict materials. The apparel side is really where it comes into play on a go-forward basis. We really need to work with our apparel vendors and sourcing channels to understand where the materials are actually coming from.
Where might conflict minerals be used in your apparel products?
It’s not going to be in the performance fabrics, which are used in a large portion of our products. But a lot of it’s potentially going to be in the zipper material. It’s at the bottom of the zipper or in the zipper pull that maybe you’ll have some tin.
Potentially, tungsten is a concern. I don’t really see us using it, but things do change. That could happen if apparel designers see something that they really like that happens to have tungsten in it. But those would be the only two. We don’t do any diamonds or gold: Our customers are not interested in wearing gold and diamonds while they’re out running.
How will you respond to the challenge of complying with the rule?
While in the past we made sure that those materials were not coming from a restricted country, the conflict rule has made us add to the number of people [performing compliance tasks]. We’ll be adding another person in 2014 to the team to help with the testing, and working with our sourcing partners around the globe to make sure that we’re in compliance.
Tracking down the country where the tin in a zipper is made sounds like quite a challenge.
It’s going to be a huge challenge for us because we work with many different suppliers and many different vendors, especially cut-and-sew vendors. We give them the specs relative to the materials that we want them to build. Then they go to the next level of supply chain to purchase the raw materials needed to provide us with the finished goods.