What is the Conflict Minerals Reporting Template (CMRT)?
Created by the Responsible Minerals Initiative (RMI, formerly the CFSI), the 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’s (EU) Non-Financial Reporting Directive and other conflict mineral laws. Under these rules, conflict minerals include tin, tungsten, tantalum and gold, also known as 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 they may have with in-scope companies. This makes the CMRT an essential tool for global conflict mineral 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 Wall Street Reform and Consumer Protection Act, the European Union (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 tin, tungsten, tantalum and gold (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 European Union (EU) markets, the answer is likely “yes.” In the U.S. context, publicly-traded companies (those required to file reports with the U.S. Securities and Exchange Commission, or SEC, under Section 13(a) or Section 15(d) of the Securities Exchange Act of 1934) must comply with the regulatory requirements laid out within the Dodd-Frank Wall Street Reform and Consumer Protection Act. If you do not have tin, tungsten, tantalum and gold (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 context, the conflict mineral rule obliges EU importers of 3TGs 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) and a manually-written declaration on conflict minerals?
The CMRT is the industry-standard template for conflict minerals reporting, and provides the most accurate and extensive information on regulatory compliance with 3TG (tin, tungsten, tantalum and gold) sourcing. The CMRT has been specifically designed to facilitate a strong due diligence process through which companies may determine the country of origin of the 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.
By contrast, declarations written manually by companies and their suppliers can be vague and typically exclude important information on these smelters, refiners and producers. This exposes companies to risks associated with failing to meet industry-level standards and regulatory requirements when reporting on conflict minerals in their supply chain.
How can I know whether tin, tungsten, tantalum or gold (3TGs) are present in my products?
If you are unsure whether the products you offer contain 3TGs, you will need to contact your own suppliers to collect this information from them. This can be done by sending them the Conflict Minerals Reporting Template (CMRT) and asking them to fill it out. By collecting this data from your own supply chain, you will be able to assess and consolidate the information for your own CMRT submission.
What is meant by “smelters” and “refiners”?
A smelter or refiner is a company that procures and processes mineral ore, slag and/or minerals from recycled or scrap sources into refined 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/
The products I supply do not contain any tin, tungsten, tantalum or gold (3TGs). Do I still need to fill out the Conflict Minerals Reporting Template (CMRT)?
Yes. Suppliers whose products do not contain 3TGs are still required to complete the CMRT and send it back to their customers. Given 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 in the template. The remaining fields in the CMRT will automatically self-populate, removing the need to fill in the rest of the template before validating it.
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 Conflict Minerals Reporting Template (CMRT)?
There are three levels a supplier can choose to declare at: “Company Level”, “Product Level” or “User Defined.” Company Level includes all the products your company makes that are covered under the CMRT. Product Level refers only to the parts and products you supply to the client on the CMRT (which you would list under the “Product” tab). User Defined allows a manufacturer to state information on any scope they feel is relevant to their declaration, such as a particular division level or business unit.
How should I submit the requested Conflict Minerals Reporting Template (CMRT) document to my customer?
When your customer asked you to complete a CMRT, they should have included details on how to submit the form. If not, contact your customer and request information on how they would like you 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 (who is an Assent client), you will receive an email requesting that you complete a new template and resend it 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 that are 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, providing as much information as possible is encouraged. Additionally, some of these columns will automatically populate when you fill in the mandatory fields. Suppliers can utilize the Checker tab to confirm all required fields have been inputted. Incomplete fields will appear in red, and completed fields will appear in green.
What should I do if I have more smelters or refiners (SORs) to report than there are columns available in the Conflict Minerals Reporting Template (CMRT)?
It is best practice to refer to the Smelter Reference List tab to validate your smelters prior to completing the Smelter List tab in the CMRT. There are approximately 320 recognized 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 list of SORs 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 Conflict Minerals Reporting Template (CMRT) last year. Why am I being asked to do this again?
Most conflict mineral rules require companies to report on conflict mineral compliance annually. 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. It is a good idea to check this with your customer to ensure you meet their requirements.
There are many versions of the Conflict Minerals Reporting Template (CMRT). Which should I use?
If your customer is an Assent client, use version 5.12 or higher. If you use an older version, you will be asked to transfer your information onto an updated template. It is always best practice to 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.