2026 Conflict and Responsible Minerals Guide: CMRT, EMRT and AMRT

Responsible-minerals reporting has become a critical part of supply-chain due diligence for manufacturers whose products may contain tin, tantalum, tungsten, gold, cobalt, copper, natural graphite, lithium, natural mica, nickel or other prioritized minerals.

In 2026, the challenge is no longer simply collecting supplier declarations. Companies must choose the correct reporting template, use a current version and verify that each response reflects the applicable reporting period and actual supply chain.

The Responsible Minerals Initiative (RMI) provides three complementary reporting tools: the Conflict Minerals Reporting Template (CMRT), Extended Minerals Reporting Template (EMRT) and Additional Minerals Reporting Template (AMRT). Each has a different mineral scope and should be used for its intended purpose.

If you are responsible for compliance, sourcing or product stewardship, outdated templates and weak supplier declarations can delay customer reporting and undermine your due-diligence process. A practical program should help you identify relevant suppliers, assess the reliability of their declarations and escalate genuine risks.

If you are responsible for compliance, sourcing, or product stewardship, you already know that outdated templates and weak supplier declarations can slow down customer reporting, create unnecessary risk, and weaken trust in your due diligence process. At Enviropass, we believe conflict minerals compliance should not be treated as a one-time administrative exercise. It should be built into a practical strategy that helps you audit your supply chain efficiently, identify real issues, and request product testing only when it is truly necessary.

Why conflict minerals due diligence still matters

Conflict minerals compliance continues to matter because customers, regulators, and downstream partners expect companies to demonstrate that they understand their supply chains. Even when a company is not directly subject to a specific legal filing obligation, it may still be required by its clients to provide a current Conflict Minerals Reporting Template and explain the basis of its declaration. In practice, that means suppliers across many industries are expected to maintain traceable and defensible information.

The OECD Due Diligence Guidance remains one of the most important reference points for building this process. According to the OECD, its minerals guidance is relevant for all companies across the entire minerals supply chain, from mines to end users, and it provides a five-step framework for risk-based due diligence in conflict-affected and high-risk areas.

For manufacturers, this means conflict minerals reporting is not just about satisfying a questionnaire. It is about showing that your organization has a repeatable method to identify relevant suppliers, collect declarations, review them critically, and respond when information is incomplete or unrealistic. A supply chain that looks organized on paper can still contain major data gaps if supplier declarations are outdated, inconsistent, or too broad to be useful.

The Latest CMRT, EMRT and AMRT Updates

One of the most important steps in 2026 is making sure your supply chain is using the latest reporting tools. The Responsible Minerals Initiative currently recommends using CMRT version 6.6, EMRT version 2.11, and AMRT version 1.31 or higher for the reporting year. All three updated versions were released on April 17, 2026.

These templates matter because they are the common language used between customers and suppliers. If one part of your supply chain is still working with an older file while another has already migrated to the newest version, the risk of misalignment increases quickly. A declaration may look complete at first glance but still fail to meet current expectations if it was created using an outdated version or obsolete smelter reference data.

Here is a simple overview of the current 2026 template versions:

Template	Current version*	Mineral scope	When to use it
CMRT	6.6	Tin, tantalum, tungsten and gold (3TG)	Collecting country-of-origin and smelter/refiner information for 3TG, including reporting associated with Dodd-Frank Section 1502 and the EU Conflict Minerals Regulation
EMRT	2.11	Cobalt, copper, natural graphite, lithium, natural mica and nickel	Extended-mineral supply-chain due diligence, including information relevant to certain EU Batteries Regulation obligations
AMRT	1.31	Up to 10 user-selected minerals not covered by the CMRT or EMRT	Collecting supply-chain information for other prioritized minerals using a flexible, mineral-agnostic template

The current mineral scopes and release information should be verified through the RMI Minerals Reporting Templates overview before beginning each reporting campaign.

Pro Tip

Download the current templates directly from the RMI rather than copying a supplier’s existing file. Before accepting a declaration, verify its version, reporting period, declaration scope, company or product scope, checker results, and facility information.

CMRT vs. EMRT vs. AMRT: Which Template Should You Use?

The three templates are complementary, but they are not interchangeable:

Use the CMRT when requesting information about tin, tantalum, tungsten and gold.
Use the EMRT when requesting information about cobalt, copper, natural graphite, lithium, natural mica or nickel.
Use the AMRT for prioritized minerals that are not covered by the CMRT or EMRT. Users may select up to 10 minerals.
Use more than one template when the supply-chain review covers minerals from multiple template scopes.

The AMRT is not an enterprise-level summary or aggregation of CMRT and EMRT responses. It is a separate supplier-reporting template for other prioritized minerals.

EMRT 2.0 was an important historical release because it expanded the EMRT beyond cobalt and natural mica to include copper, natural graphite, lithium and nickel. It also introduced an optional mine-level facility tab. However, EMRT 2.0 is no longer the current version; new reporting campaigns should normally use EMRT 2.11.

How to ensure your declarations are valid

A returned declaration is not automatically a valid declaration. This is one of the most common mistakes in conflict minerals programs. Many companies measure success by the number of files received, when they should also be evaluating the quality and plausibility of those files.

The first step is to verify the checker tab. The reporting templates are designed to identify missing data, logical inconsistencies, and formatting problems. If the checker tab shows unresolved issues, the declaration should not be considered final. A supplier may have responded, but that does not mean the response is usable for your own reporting.

The second step is to review the declaration more critically. Does it correspond to the right reporting year? Is it a company-level declaration or a product-level declaration? Does that match what you requested? Does the contact information make sense? Are the answers internally consistent from one tab to another? These questions sound basic, but they often reveal important weaknesses.

You should also examine the smelter data carefully. Are the declared smelters realistic for the supplier’s products? Are the CIDs valid and properly identified? Are the listed facilities aligned with the type of mineral being reported? A declaration that contains vague, duplicated, or implausible smelter information should be flagged for follow-up instead of being accepted without review.

Conflict Minerals Checklist

A practical validation checklist often includes the following points:

Latest template version used
No unresolved checker errors
Correct reporting year
Scope aligned with the request
Supplier contact details clearly identified
Smelter entries realistic and traceable
CID references valid where applicable
No contradictory answers or suspicious country data

The Responsible Minerals Initiative also maintains public facility references that companies can use to determine whether a facility participates in RMI assessments, which makes smelter plausibility review a key part of declaration validation.

Pro Tip

Aim to get as close as possible to a full response rate from your supply chain, but do not stop there. Careful follow-up is what separates a collected declaration from a reliable declaration. You should also flag banned countries, invalid information, unrealistic smelter entries, and declarations that do not match the supplier’s actual business with you.

Build a robust due diligence system

Strong conflict minerals compliance does not come from last-minute file collection. It comes from a due diligence system that is structured, documented, and maintained over time. The OECD five-step framework starts with establishing strong company management systems, then assessing risk, responding to risk, supporting independent audit practices upstream where relevant, and reporting annually on due diligence.

In practical terms, this means having a written procedure. Your organization should know who owns supplier outreach, who validates declarations, how suppliers are selected, what escalation criteria are used, and how records are stored. Without a procedure, the process depends too much on individual habits and becomes difficult to defend during customer reviews or audits.

A robust system also starts with a clean supplier list. Begin by listing the active suppliers that were relevant over the calendar-year period. Then clean the list. Remove duplicates, archive inactive suppliers, and separate vendors whose products are clearly outside conflict minerals scope. For example, some plastic-only purchases may not justify the same level of follow-up as metal components, electronic assemblies, coatings, fasteners, or solder-containing parts.

This filtering step is essential because it improves both efficiency and data quality. If your team sends declarations to every vendor without qualification, you waste time and dilute your efforts. When you focus on suppliers linked to products that may actually contain conflict minerals, your outreach becomes more credible and your review process becomes easier to manage.

Supplier communication is another major pillar. Your suppliers need to understand your policy, the reason for the request, and what a complete declaration should look like. Many low-quality responses are caused less by resistance than by confusion. When suppliers are educated properly, response quality tends to improve year after year.

The OECD guidance is especially helpful here because it frames due diligence as an ongoing, risk-based process rather than a one-time check. That mindset helps companies move away from reactive reporting and toward a system that is more resilient and easier to repeat.

Pro tip

Follow the OECD guidance and stay alert to updates and recommendations coming from the Responsible Minerals Initiative and specialized consultants. The companies that handle conflict minerals well are usually the ones that treat due diligence as a living management process, not as an annual spreadsheet exercise.

The various CMRT, EMRT and AMRT versions

To audit your supply chain effectively, it helps to understand that these templates have evolved over time for good reason. New versions are released to correct technical issues, improve data consistency, align with evolving supply chain needs, and update reference lists used by reporting companies.

This matters because some suppliers continue to recycle old templates long after a new version is available. That creates reporting friction. A buyer may ask for the latest template, while the supplier assumes an older file is still acceptable because it was used the year before. This gap leads to repeated clarification requests, incomplete submissions, and extra administrative burden on both sides.

The 2026 cycle is a good example. The MRT introduction page published by the Responsible Minerals Initiative confirms that the latest versions of CMRT, EMRT, and AMRT were all released on April 17, 2026. The AMRT page specifically notes updated ISO short names, a corrected date input issue, and updated smelter reference materials. These may look like small technical changes, but in practice they affect the quality, comparability, and reliability of declarations across the supply chain.

Companies that do not monitor version history often run into the same problem every year: suppliers submit declarations that are complete according to their own standards, but incomplete according to the customer’s current requirements. Version awareness is therefore a practical business discipline, not just a technical detail.

Are CMRT 6.1, CMRT 6.22, CMRT 6.5 and EMRT 2.0 Still Current?

No. CMRT 6.1, CMRT 6.22, CMRT 6.5 and EMRT 2.0 are historical versions and should not be presented as the latest RMI templates.

Retain completed historical templates as part of the applicable reporting-period records. However, for a new supplier campaign, request the current RMI version unless a customer specifically requires another version or the campaign was already underway when a new version was released.

Do not automatically transfer responses from an older template. Reconfirm the reporting period, declaration scope, supplier information, mineral scope and identified facilities before relying on previously submitted data.

Here is why template evolution should matter to you:

Why templates evolve	What it means for your audit process
Smelter reference data changes	Older declarations may no longer reflect current facility data
Validation logic improves	Files that once passed may no longer be acceptable
Scope and field structure evolve	Product and supplier information may need to be reported differently
Technical issues get corrected	Current files reduce avoidable errors and inconsistencies

Pro tip

Subscribe to trusted update sources and monitor template releases before starting your annual declaration cycle. It is far easier to control version consistency at the start of the process than to correct mismatched files after suppliers have already responded.

A better conflict minerals strategy in 2026

The most effective strategy is not simply to test more or collect more. It is to build a system that helps you audit your supply chain and reserve testing for the cases where it is actually needed. That requires a combination of supplier mapping, declaration review, process discipline, and informed escalation.

A smart strategy also recognizes that not every supplier presents the same level of risk. Some suppliers are clearly in scope, highly relevant, and connected to materials or components that warrant detailed review. Others may be low-risk or outside the scope of your products altogether. Treating them the same creates unnecessary work without improving your due diligence outcome.

At Enviropass, we help companies build turnkey solutions that fit their actual needs. That may mean helping you define scope, clean supplier lists, validate declarations, challenge unrealistic smelter entries, improve supplier follow-up, or support your broader annual reporting process. The right approach depends on whether you need support at the company level, the product level, or both.

Conflict and Responsible Minerals FAQ

What Are Conflict Minerals, and Why Are They Regulated?

Under the U.S. conflict-minerals rule, the term covers tin, tantalum, tungsten and gold—commonly known as 3TG—regardless of their country of origin. The disclosure analysis then considers whether necessary 3TG may have originated in the Democratic Republic of the Congo or an adjoining country.

Conflict-minerals requirements are intended to improve supply-chain transparency and reduce the risk that mineral extraction or trade finances trade finances armed groups or contributes to serious human-rights abuses.

The EU Conflict Minerals Regulation separately establishes due-diligence obligations for certain EU importers of 3TG originating from conflict-affected and high-risk areas.

What does 3TG stand for?

3TG refers to:

Tin (Sn): commonly used in solder, coatings and plating.
Tantalum (Ta): commonly used in capacitors and high-performance electronic components.
Tungsten (W): commonly used in tooling, weights, contacts and vibration components.
Gold (Au): commonly used in connectors, contacts, bonding wires and coatings.

What Is the U.S. DRC Conflict Minerals Rule?

SEC Rule 13p-1 applies to certain Exchange Act reporting companies that manufacture or contract to manufacture products for which 3TG are necessary to functionality or production.

A covered company must first conduct a good-faith reasonable country-of-origin inquiry. Depending on the results, additional source and chain-of-custody due diligence and a Conflict Minerals Report filed as an exhibit to Form SD may be required. A Conflict Minerals Report is not automatically required in every case.

The SEC has also published enforcement guidance following court decisions affecting parts of the rule. Companies subject to SEC reporting should confirm their current filing obligations with qualified legal counsel.

What is the CMRT?

The Conflict Minerals Reporting Template is a standardized RMI tool that facilitates the exchange of information about 3TG country of origin and the smelters and refiners used within a supply chain.

A completed CMRT is supporting due-diligence information. It does not, by itself, prove that a product is conflict-free or that a company has satisfied every applicable legal obligation.

The RMI does not collect completed CMRTs. They are normally provided to requesting customers and may also be published by the responding company.

What Is the Difference Between the CMRT, EMRT and AMRT?

The CMRT covers tin, tantalum, tungsten and gold. The EMRT covers cobalt, copper, natural graphite, lithium, natural mica and nickel. The AMRT allows users to select up to 10 other minerals that are not covered by the CMRT or EMRT.

Select the template according to the minerals being investigated. A company may need more than one template, but the AMRT should not be used as a consolidated summary of CMRT and EMRT results.

Can an Older Template Still Be Accepted?

An older template may remain useful as evidence for the reporting period in which it was completed. Its acceptability depends on the customer’s requirements, reporting period, mineral scope and quality of the information.

For a new campaign, use the current RMI version unless the requesting customer specifies otherwise. Never describe CMRT 6.1, CMRT 6.22, CMRT 6.5 or EMRT 2.0 as the latest version.

What Is OECD Minerals Due Diligence?

The OECD Due Diligence Guidance provides a five-step, risk-based framework under which companies:

Establish strong company management systems.
Identify and assess supply-chain risks.
Design and implement a strategy for responding to identified risks.
Support independent third-party audits at appropriate points in the supply chain.
Report annually on their supply-chain due diligence.

The guidance is not merely a supplier questionnaire. It describes an ongoing management process that should be proportionate to the company’s position, identified risks and available influence.

What Can Happen When Due-Diligence Obligations Are Not Met?

The consequences depend on the applicable law, contractual requirements and the company’s role in the supply chain. They may include regulatory scrutiny, rejected customer submissions, corrective-action requests, reporting delays, loss of business, audit findings and reputational harm.

Conclusion

Conflict minerals compliance in 2026 demands more than sending a template and waiting for replies. You need current tools, valid declarations, a disciplined review process, and a due diligence system that can stand up to customer and market expectations. The latest CMRT, EMRT, and AMRT versions, along with the OECD due diligence framework, make it clear that reliable reporting depends on both accurate supplier data and a strong internal process.

At Enviropass, we are here to help you audit your supply chain on your behalf. We bring years of experience, practical expertise, and direct knowledge of how to strengthen conflict minerals declarations without turning compliance into unnecessary complexity. Whether you need a turnkey solution at the company level or a more targeted review at the product level, we help you build a conflict minerals strategy that fits your reality.

Strengthen Your Conflict Minerals Strategy

Audit your supply chain with confidence

Conflict and responsible-minerals due diligence in 2026 demands more than sending templates and waiting for replies. We help you build a practical, reliable conflict minerals process tailored to your products, suppliers, and reporting needs.

Last reviewed: August 18, 2026