Risk & Traceability

Related Coverage

Software Quotes

Last updated: October 2026



Conflict Minerals Reporting (CMRT and EMRT)

Conflict minerals rules require companies to trace where certain metals in their products were mined and to show that their purchases do not finance armed groups or serious human rights abuses. The original scope is the 3TG metals - tin, tantalum, tungsten and gold - all of which are used throughout electronics in solder, capacitors, contacts and plating. Customer and battery rules have since extended reporting to cobalt, mica and other battery minerals.

United States - Dodd-Frank Section 1502

Section 1502 of the Dodd-Frank Act, implemented by SEC Rule 13p-1, applies to SEC-registered companies that manufacture or contract to manufacture products containing 3TG. Those companies must conduct a reasonable country of origin inquiry (RCOI) and file Form SD each year by May 31, covering the prior calendar year. Where 3TG may come from the Democratic Republic of the Congo or an adjoining country, a Conflict Minerals Report describing due diligence is attached. Suppliers to SEC registrants receive the reporting requests even when they are not registrants themselves.

European Union - Conflict Minerals Regulation

Regulation (EU) 2017/821 applies to EU importers of 3TG ores, concentrates and metals above annual volume thresholds set in its Annex I. Covered importers must run supply chain due diligence aligned with the OECD Due Diligence Guidance, obtain third-party audits and report publicly. Recycled metals are generally excluded. Downstream manufacturers are not directly covered, but their smelter data is requested by customers who are.

RMI reporting templates

  • CMRT (Conflict Minerals Reporting Template) - the standard spreadsheet for 3TG smelter and refiner data, used for Dodd-Frank and EU reporting.
  • EMRT (Extended Minerals Reporting Template) - covers cobalt and mica, and with EMRT 2.0 adds copper, natural graphite, lithium and nickel to support EU Battery Regulation due diligence.
  • AMRT (Additional Minerals Reporting Template) - a flexible template for other minerals a customer chooses to trace.

The templates are published by the Responsible Minerals Initiative (RMI). Its Responsible Minerals Assurance Process (RMAP) audits smelters and refiners, and the RMAP conformant list is how reporting companies judge whether a declared smelter is acceptable.

Battery minerals

The EU Battery Regulation adds supply chain due diligence for cobalt, lithium, nickel and natural graphite in batteries; Regulation (EU) 2025/1561 postponed that obligation to August 18, 2027. The Responsible Business Alliance (RBA) Code of Conduct also extends its minerals expectations to cobalt, so electronics customers increasingly request EMRT data alongside the CMRT.

Reporting workflow

  1. Identify parts and materials that contain 3TG, cobalt, mica or battery minerals.
  2. Send CMRT and EMRT requests to direct suppliers and collect smelter and refiner lists.
  3. Check declared smelters against the RMAP conformant list and follow up on non-conformant or unknown entries.
  4. Roll up a company-level CMRT and EMRT for customers, and prepare Form SD where required.

Related coverage