What Is the CMRT?
Created by the Responsible Minerals Initiative (RMI, formerly the CFSI), the Conflict Minerals Reporting Template (CMRT) is an industry-standard reporting template that helps companies perform their due diligence by disclosing smelter information gathered from their supply chain.
The CMRT is an important tool for companies and their suppliers in scope of conflict mineral regulations such as Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the European Union (EU)'s Non-Financial Reporting Directive and other conflict minerals laws. Under these regulations, conflict minerals include tin, tungsten, tantalum and gold (3TGs), originating in the Democratic Republic of the Congo (DRC) or any of the “Covered Countries” under these regulations. Out-of-scope companies are not excused from performing due diligence, as reporting 3TG sourcing could be a requirement for any contracts with in-scope companies. This makes the CMRT an essential tool for global conflict minerals compliance.
How Does the Conflict Minerals Reporting Template (CMRT) Work?
The CMRT is available as a free-to-download Excel file. It is comprised of several tabs and questions on various aspects of conflict mineral compliance and is highly effective for supporting mandatory conflict mineral disclosures under the Dodd-Frank Act, the EU Non-Financial Reporting Directive and other similar laws. Companies distribute the template to their suppliers, who fill in their responses and return the template to their customers. Based on the answers provided in the CMRT, the data can be analyzed to determine the location of 3TGs within supply chains, identify risks, and make informed compliance and sourcing decisions.
Am I Required to Comply With Conflict Mineral Laws?
If you have a contract with a company operating in the U.S. or EU markets, the answer is likely “yes.” In the U.S., publicly-traded companies are required to file reports with the U.S. Securities and Exchange Commission (SEC) under Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934, and must comply with Dodd-Frank Act requirements. If you do not have 3TGs in your supply chain, you must still submit that information to your customer so they can complete their conflict mineral due diligence activities.
In the EU, the conflict minerals rule require 3TG importers to undertake due diligence to ensure their supply chains are not fueling armed conflicts in the Democratic Republic of the Congo (DRC) and surrounding countries. The same is true of the EU Non-Financial Reporting Directive.
Other regulations and standards you may be required to provide CMRTs for include Chinese conflict mineral regulations, corporate social responsibility (CSR) standards and more.
What Is the Difference Between the Conflict Minerals Reporting Template (CMRT) & a Manually-Written Declaration on Conflict Minerals?
The CMRT is the industry-standard template for conflict minerals reporting, facilitating compliance with 3TG sourcing regulations and other requirements. The CMRT has been specifically designed to support companies conducting due diligence to determine the country of origin for 3TGs in their supply chains. To achieve this, the CMRT is passed along the supply chain, enabling companies to identify problematic smelters and producers in their sourcing activities. This identification is a vital step in confirming your supply chain is conflict-free.
In contrast to the CMRT, declarations that companies and suppliers write manually can be vague and typically exclude important information about smelters, refiners and producers. This exposes companies to the risks associated with failing to meet industry standards and regulatory requirements when reporting on conflict minerals in their supply chain.
How Can I Know Whether 3TGs Are Present in My Products?
If you are unsure whether your products contain 3TGs, you will need to contact your suppliers to collect this information. This can be done by sending them the Conflict Minerals Reporting Template (CMRT) and asking them to fill it out. Once this data is collected from your supply chain, you can assess and consolidate the information for your own CMRT submission.
What Is Meant by “Smelters” & “Refiners”?
A smelter or refiner is a company that procures and processes mineral ore, slag and/or minerals from recycled or scrap sources, and refines the materials into metal or metal containing intermediate products. The two terms are often used interchangeably in various publications. The names of recognized smelters can be found in the “Smelter Reference List” tab of the Conflict Minerals Reporting Template (CMRT).
For more information on legitimate smelters and how these facilities are audited for conflict-free sourcing practices, see the Responsible Minerals Initiative (RMI) website at http://www.responsiblemineralsinitiative.org/
Do I Need to Fill Out the CMRT if the Products I Supply Do Not Contain 3TGs?
Yes. Suppliers whose products do not contain 3TGs are still required to complete the CMRT and send it back to their customers. As there is nothing to disclose in these cases, the process is very simple. Suppliers should fill in the “Company Information” section at the top of the template, and then answer “No” to questions one and two. The remaining fields will automatically self-populate, removing the need to fill in the rest of the template before it's validated.
To learn about common mistakes and best practices when completing your CMRT, check out our comprehensive article here.
How Do I Know Which “Scope” to Declare on the CMRT?
There are three levels a supplier can choose to declare at: “Company Level,” “Product Level” or “User Defined.” The Company Level scope includes all the products your company makes that are covered under the CMRT. The Product Level scope refers only to the parts and products you supply to the client on the CMRT (which you would list under the “Product” tab). The User Defined scope allows manufacturers to state information on any scope they feel is relevant to their declaration, such as a particular division level or business unit.
How Do I Submit a CMRT to My Customer?
When your customer requested that you complete a CMRT, they should have included details on how to submit the form. If not, contact your customer to find out how to submit the CMRT.
If your customer is an Assent Compliance client, you will receive an email requesting the CMRT along with a unique link to your very own Supplier Portal. This portal allows you to easily submit your file and any supporting documentation directly to your customer’s compliance manager. If you have any additional questions about this process, your email also contains contact information to request support.
If you submit an invalid CMRT to your customer that is an Assent client, you will receive an email requesting that you complete a new template to resend to the customer. An invalid template can be the result of a number of factors, including incomplete tabs or fields (highlighted in red), and can also occur when an old template is used instead of the most up-to-date version.
Do I Need to Complete Columns Not Marked as “Required” in the Smelter Tab?
You only need to complete the required fields (indicated with an asterisk) for the template to be marked as completed. However, your are encouraged to provide as much information as possible. Additionally, some columns automatically populate when you fill in the mandatory fields. Suppliers can utilize the Checker tab to confirm all required fields have been completed. Incomplete fields will appear in red, and completed fields will appear in green.
What Should I Do if I Have More Smelters or Refiners to Report Than There Are Columns Available in the Conflict Minerals Reporting Template (CMRT)?
The best practice is to validate your smelters using the Smelter Reference List tab prior to completing the Smelter List tab in the CMRT. There are approximately 320 recognized smelters or refiners (SORs) around the world, for which space has been provided on the CMRT. If, however, one of your SORs does not appear on the list, there is the option to select “Smelter Not Listed” from the dropdown menu. From here, you can enter the new SOR name. You should then provide additional information on why this facility may be an unrecognized smelter in the subsequent columns.
Finally, be sure to review your SOR list and remove any duplicates that may be present, along with names that do not refer to smelters (such as supplier, distributor or manufacturer names).
I Already Completed a CMRT) Last Year. Why Am I Being Asked to Do This Again?
Most conflict mineral rules require companies to annually report on conflict minerals compliance. This means suppliers will be asked to complete a new CMRT every year in advance of the reporting deadline. In the U.S., the standard deadline for reporting is May 31, but this may differ for some industries and other global conflict mineral regulations. Check with your customer to ensure you are meeting their requirements.
There Are Many Versions of the CMRT. Which Should I Use?
If your customer is an Assent client, use version 6.01 or higher. If you use an older version, you will be asked to transfer your information onto an updated template. The best practice is to always use the most up-to-date version of the CMRT.
To download the latest version of the CMRT, click here.
For additional information on conflict minerals, download a copy of Assent's eBook The Conflict Mineral Handbook: Your Guide to Compliance in 2019.