The Responsible Minerals Initiative (RMI) has released version 1.21 of the Additional Management Reporting Template (AMRT)—marking a significant advancement in promoting ethical sourcing and regulatory compliance across the global minerals supply chain.
While companies often prioritize templates like the CMRT (Conflict Minerals Reporting Template) and EMRT (Extended Minerals Reporting Template), the AMRT plays a distinct and equally vital role. It focuses directly on smelters and refiners, enabling them to report their due diligence efforts under the Responsible Minerals Assurance Process (RMAP). These facilities serve as the chokepoint of the mineral supply chain and are critical to any responsible sourcing strategy.
This blog explores the technical upgrades, contextual importance, strategic benefits, and best practices for using AMRT 1.21—so you’re not just informed, but fully prepared to act.
To appreciate the significance of version 1.21, it’s vital to understand the AMRT’s core function. While the CMRT and EMRT are downstream-focused, the AMRT is primarily used by upstream entities—namely, smelters and refiners—to:
In doing so, the AMRT helps smelters demonstrate conformance with due diligence frameworks, such as the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs).
Moreover, AMRT responses form a foundation for downstream companies’ sourcing declarations. Without reliable, transparent input from smelters, companies further down the chain would struggle to build credible compliance programs.
The release of AMRT 1.21, in May 2025, brings targeted updates that improve usability, consistency, and regulatory alignment. While previous versions already provided a basic structure, version 1.21 addresses critical pain points identified through stakeholder feedback and audit observations.
Previously, the AMRT did not differentiate clearly between corrective actions “planned,” “in progress,” or “completed.” This version introduces structured fields and dropdown menus to specify the exact stage of audit responses, adding valuable context for stakeholders evaluating supplier maturity.
Socially responsible investors and civil society organizations increasingly demand greater transparency. They scrutinize smelters’ audit status and sourcing practices, and any ambiguity can damage reputations and drive away business. AMRT 1.21 addresses this risk by providing more granular, auditable data.
To minimize input errors, dropdowns have been introduced for data fields like country of origin, audit firm, and conformance status. This change not only reduces inconsistencies but also simplifies data validation across multiple templates.
Terms such as “compliant” and “certified” are now clearly distinguished from “RMAP-conformant,” reinforcing the RMI’s preference for neutral, fact-based language that avoids overstatement of a facility’s standing.
Data fields in AMRT 1.21 have been mapped to relevant entries in other RMI templates. This facilitates cross-template analysis, especially for organizations using multiple tools to manage 3TG, cobalt, and mica simultaneously.
The timing of AMRT 1.21 reflects both regulatory evolution and practical necessity. Several recent developments created urgency for an update:
The EU Conflict Minerals Regulation, now fully in force, requires importers of 3TG to conduct extensive due diligence—much of which hinges on smelter data.
Similarly, the German Supply Chain Due Diligence Act (LkSG), effective since 2023, mandates that companies assess human rights and environmental risks throughout their global supply chains.
Meanwhile, updated laws are emerging in countries like Canada, France, and the United States, placing additional pressure on supply chain actors to ensure end-to-end traceability.
Stakeholders—including socially responsible investors and civil society organizations—are demanding greater transparency. Any ambiguity in a smelter’s audit status or sourcing practices can lead to reputational damage and loss of business. AMRT 1.21 helps mitigate this risk by offering more granular, auditable data.
Audit firms working under the RMAP framework flagged several areas where template inconsistencies led to delays or misunderstandings. The 1.21 update reflects direct input from these auditors, who emphasized the need for structured fields, clearer definitions, and supporting examples.
Although only smelters and refiners are required to submit the AMRT as part of RMAP, many other actors across the supply chain benefit from it, including:
OEMs and Tier 1 suppliers, who can use AMRT data to verify the legitimacy of declared smelters.
Consultants and service providers, who assist in due diligence mapping and traceability exercises.
Auditors, who rely on consistent and detailed AMRT submissions for risk assessment.
Download the template from the RMI website.
Review the changes by comparing 1.21 with version 1.20.
Train staff who manage audit preparation and data entry.
Migrate historical data and verify compatibility with CMRT and EMRT files.
Engage with your RMI liaison or a compliance advisor to ensure you interpret fields correctly.
Though completing the AMRT may appear administrative, doing so correctly brings significant strategic benefits:
Audit readiness: Better documentation equals smoother and faster RMAP audits.
Stakeholder assurance: Investors, customers, and regulators gain confidence in your due diligence practices.
Competitive edge: Conformant smelters are often prioritized in procurement decisions.
Risk management: Proactive disclosure reduces exposure to regulatory penalties and public criticism.
ESG alignment: A completed AMRT supports Environmental, Social, and Governance (ESG) reporting frameworks such as GRI, SASB, and CSRD.
As mineral supply chains become more complex, digitized, and regulated, templates like the AMRT will continue evolving. While AMRT 1.21 offers tangible improvements, future versions may integrate:
Blockchain-based traceability
Automated risk scoring
Supplier performance dashboards
AI-driven anomaly detection
In short, the AMRT is not just a document—it’s a building block for digital supply chain governance.
The release of AMRT 1.21 is far more than a routine update. It reflects a broader shift toward rigorous, transparent, and standardized responsible sourcing practices. By offering greater clarity, usability, and alignment with global norms, this version empowers smelters, refiners, and downstream companies alike to raise the bar in due diligence.
Therefore, adopting AMRT 1.21 isn’t simply about compliance—it’s about leadership in ethical supply chain management.
If your company touches any part of the mineral value chain, now is the time to integrate AMRT 1.21 into your workflow and show your stakeholders you’re committed to transparency, responsibility, and continuous improvement.
Contact Enviropass to learn more about AMRT!
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