CMRT 6.4 and EMRT 1.3

RMI released the new version of the Conflict Minerals Reporting Template, CMRT 6.4, in late April 2024. In the same period, the organization published the new Extended Minerals Reporting Template, or EMRT.

CMRT 6.4

The Conflict Minerals Reporting Template (CMRT), developed by the Responsible Minerals Initiative (RMI), is a standardized reporting tool that enables the seamless exchange of information across supply chains regarding the origin of minerals and the utilization of smelters and refiners. Additionally, it aids in identifying new smelters and refiners for potential assessment through the Responsible Minerals Assurance Process (RMAP).

To access the CMRT Template, you can download the latest version (6.4). RMI recommends utilizing CMRT version 6.4 or newer for the Reporting Year.
Additionally, access the most current Smelter Reference List and revision history.

Changes incorporated in CMRT version 6.4, released on April 26th, 2024, encompass the following:

corrections of reported bugs and errors,
updates to highlighting on the Smelter List tabs, and
revisions to the Smelter Reference List and Standard Smelter List.

The iterations of the CMRT are typically available in the Spring of each year.

EMRT Version 1.3

The Extended Minerals Reporting Template (EMRT) is a standardized reporting tool created by the RMI to pinpoint critical areas and gather due diligence data within cobalt and mica supply chains. Officially launched in October 2021, RMI recommends EMRT version 1.3 or newer for the Reporting Year.

To obtain the template, download the latest version (1.3). Changes introduced in EMRT version 1.3 (released the same day as CMRT, 26th April 2024) include:

bug and error corrections,
updates to highlight features on Smelter List tabs,
revisions to the Smelter Reference List and Standard Smelter List, and the addition of a German translation to the file.

Like CMRT, one can anticipate the next EMRT version to be available in Spring 2025.

For cobalt and mica supplier reporting, please utilize EMRT. RMI phased out the Cobalt Reporting Template (CRT) and Mica Reporting Template (MRT) on March 31st, 2022.

Here is a list of currently identified cobalt refiners and mica processors. This list may expand as more cobalt refiners and mica processors are confirmed.

The RMI has notified of modified versions of the Extended Minerals Reporting Template and an unofficial Raw Materials Reporting Template (RMRT) circulating. The RMI only acknowledges Minerals Reporting Templates developed through its cross-industry consensus process.

Why CMRT 6.4 Matters

Typically, organizations develop a Conflict Minerals Reporting Template or policy to address the origin of minerals within their scope.

As per the RMI, 3TG Minerals The American Dodd-Frank Act regulates declarations of 4 conflict minerals known as 3TG (tin, tantalum, tungsten, and gold) originating from mines in the Democratic Republic of the Congo (DRC).

Similarly, the European Union has enacted Regulation # 2017/821, imposing supply chain due diligence obligations for Union importers of tin, tantalum, tungsten, their ores, and gold originating from conflict-affected and high-risk areas.

What are Conflict Minerals?

3TGs in DRC Slavery Associated with Conflict Minerals from Mine to Smelter Conflict minerals include tin (Sn), tantalum (Ta), tungsten (W), and gold (Au). These minerals, commonly referred to as 3TGs, originate from conflict areas such as:

Democratic Republic of the Congo (DRC) and
Its neighboring covered countries: Angola, Burundi, Central African Republic Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia, and Democratic Republic of Congo – Conflict Minerals Specifically, mines in the Kivu provinces, Eastern DRC, face a high risk of being under terrorist control.

Uses of 3TGs

Tin: Essential in applications like solder.

Tantalum: Found in electronic components such as capacitors.

Tungsten: In electronics, electrical equipment, and alloys.

Gold: Utilized in electronics, notably circuit boards, as well as in jewelry, currency, medicine, and even cuisine!

Cobalt and Mica as Conflict Minerals

Although current legislation primarily addresses 3TGs, other minerals like cobalt and mica pose similar conflict concerns. These minerals are essential in electrical and electronic equipment, prompting the RMI to introduce the Extended Minerals Reporting Template (EMRT) to address them.

Cobalt is extensively used in batteries, while mica finds application in various products like plastics, insulations, capacitors, magnets, and paints.

What about Rare Earth Elements?

Periodic Table Rare Earth Elements Rare earth elements (REEs) consist mainly of the fifteen lanthanides on the periodic table. These elements are crucial in electronics, automotive, aerospace, and military industries.

China holds a near-monopoly on some REEs, raising strategic and political concerns. Moreover, the extraction of REEs is highly polluting. Presently, no specific legislation regarding the origin of REEs is in place.

CMRT 6.4 Requirements

Since March 2014, any company listed on Wall Street must annually disclose the origin of these minerals used in production, as per the SEC (Securities and Exchange Commission).

Among other obligations, companies must declare whether:

Their products contain any of the 3TGs. They have established a responsible minerals sourcing policy. All smelters in the supply chain have provided sourcing information. SEC Securities and Exchange Commission

The CMRT CMRT stands for Conflict Minerals Reporting Template.

Content of the CMRT 6.4

Key tabs in the Excel CMRT include:

Declaration tab: Company credentials and conflict minerals details. Smelter List tab: Reports on smelters in the supply chain.

Checker tab: Highlights missing information.

Product List: References to in-scope products, if applicable.

The CMRT is regularly updated, correcting errors and updating the Smelter list. Therefore, it’s advisable to request the latest CMRT versions from suppliers.

Responsible Minerals Initiative RMI and the CMRT 6.4

The RMI is a nonprofit organization providing resources and tools for conflict-free sourcing.

RMI’s Activities Aside from maintaining the CMRT, the RMI conducts auditing programs of smelters to ensure conflict-free mineral sourcing.

Auditors follow guidelines and protocols to ascertain whether smelters and refiners exclusively purchase conflict-free minerals.

Conflict Minerals Ore

Who Should File a Conflict Minerals Reporting Template? Impacted companies include any entities involved in extracting or using 3TGs in production, from mines to finished goods manufacturers. These organizations are:

Local and international ore traders.
Smelters and refiners.
Component producers.
Assemblers.

Conflict mineral laws affect electronics manufacturers, as these products typically contain at least one 3TG.

There is no de minimis threshold exempt from reporting obligations.

Directly Impacted Companies

Approximately 6,000 public US companies (per SEC) and their suppliers may be subject to CMRT inquiries. All sectors, including medical and defense industries, are within scope.

Contributors to CMRT 6.4 Inquiries

Even entities not directly dealing with US public companies may be part of their supply chain, necessitating reporting on the origin of 3TGs in products for commercial reasons.

Why are Conflict Minerals Regulations Necessary?

The DRC has faced protracted conflict, resulting in massive human rights abuses and displacement.

Approximately 8 million people have died since 1994, with millions displaced. Rebels have been responsible for genocide, planned rapes, and forced child labor, often in mines under their control.

In July 2010, the USA aimed to disrupt revenue streams from mines under rebel group control, leading to the enactment of Conflict Minerals Regulations. These regulations originated during the Obama administration and continued under subsequent governments.

The European Union also introduced similar regulations in 2017.

Other conflict-affected and high-risk areas (CAHRAs) are also identified, per EU legislation.

Conflict Minerals Regulations and OECD Guidance

The Dodd-Frank Act’s section 1502 governs Conflict Minerals Regulations in the USA, starting in August 2012.

The EU’s conflict minerals bill, effective from January 2021, aligns with this framework.

Since 2011, the OECD has updated the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. Although not legally binding, these guidelines help mitigate risks associated with conflict minerals in supply chains.

Purpose of the CMRT 6.4 and Audit Approach

The primary goal of conflict minerals legislation is to deprive rebel groups of financial resources, offering an alternative to military intervention.

Smelters and refiners worldwide play a critical role in the supply chain by purchasing recycled metals or new ore. Auditors assess these entities to ensure they exclusively acquire conflict-free minerals.

A 2017 study by Elm Sustainability Partners estimated the annual industry cost of fulfilling Dodd-Frank Act conflict minerals reporting obligations at $600 to $800 million.

Toward Conflict-Free Minerals?

Despite challenges, there has been a significant increase in conflict-free smelters and refiners over the years, signaling progress. However, armed groups continue to operate, finding alternative funding sources.

Find free resources on social compliance, including conflict minerals. Contact Enviropass for any specific questions.