Question: When a smelter is removed from the known smelter list, is there a grace period before it is formally removed from the certified smelter list? What is a reasonable time period for our suppliers to wait before removing this smelter from their Conflict Minerals Reporting Template (CMRT)?
Answer: Removing a smelter from the known list is very different than removing them from the certified list. If a smelter has been removed from the known list, they no longer refine metals or have never been defined as a smelter or refiner, and the removal is a correction.
However, if the supplier has identified a smelter as a possible upstream source, we don’t recommend removing them from your disclosure, regardless of their compliance status. Often, tin refineries — especially those in Southeast Asia — open and close based on current incoming materials that have yet to be processed. It’s very common for them to shut their doors as they negotiate concessions from various mining sites. If that closure period falls during their audit renewal, they often won’t pay to be re-audited until they have more stock and are ready to re-open.
There may also have been changes to the audit process. Some tin smelters may not be listed because of a recent rewrite to their process. Additionally, oversight could shift toward the International Tin Association before the end of the year. Although this may further delay some smelters, it will strengthen the due diligence process by requiring internationally traded tin brands to comply with best practice auditing standards.
Content is current as of 2019 09-13.