What is this request about?
With the Conflict Minerals request, companies want to determine whether their products contain tin, tungsten, tantalum or gold, regardless of where they are sourced from. Since most companies can’t determine this themselves, they survey their supply chain to gather this information so they are able to report.
It’s important to know that we need a CMRT 6.1 from you regardless of whether your parts/products contain any of the 3TGs or not. It also doesn’t matter where the 3TGs are sourced from, if you have them in your parts/products you need to declare them. It is not forbidden to obtain 3TGs from the DRC and adjacent countries, it’s only certain smelters in that area that are linked to finance or benefit armed groups.
How do I start?
You can start by sending a blank CMRT to all of your relevant suppliers with the request to fill it out. Typically, the CMRT is passed down the supply chain to the point where it can be identified where the minerals are being refined and melted.
Once your suppliers send the completed questionnaire’s back to you, you will have all the information required to complete your own CMRT. The goal of a CMRT is to determine whether tin, tungsten, tantalum or gold is present in your parts/products, regardless of where they are sourced and in which parts/products the minerals are contained. You don’t have to wait for all your suppliers to get back to you before you create your own CMRT, you can identify the percentage of feedback you received with questions 6.
Why is my customer asking me for this information?
Some companies have to do this because they have to report their findings to the U.S. Securities and Exchange Commission (SEC), some have to do this because of customer requests and other companies do this to be diligent of where the material in their parts/products come from. For a lot of industries, whether they are required to report or not, gathering conflict minerals information has become best practice.