By Deepa Shetty | Thu Mar 23 2023 | 2 min read

Table of Contents

The Conflict Minerals Reporting Template (CMRT) is a standardized tool designed to help companies collect and disclose data on the use of conflict minerals—tin, tungsten, tantalum, and gold (3TG) in their supply chains. Managed by the Responsible Minerals Initiative (RMI), the CMRT aligns with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs).

What is the Purpose of the CMRT?

The CMRT is a global tool used across industries to promote supply chain transparency and compliance with conflict minerals regulations. Its primary purposes include:

  • Data Collection: Facilitating the collection of supplier data on 3TG minerals within the supply chain.
  • Compliance Reporting: Helping companies meet the requirements of the U.S. Dodd-Frank Act Section 1502 and the EU Conflict Minerals Regulation.
  • Public Disclosure: Enabling businesses to disclose sourcing information to investors, customers, and other stakeholders.
  • Smelter Identification: Supporting the RMI’s Responsible Minerals Assurance Process (RMAP) by identifying new smelters and refiners for potential audits.

The latest CMRT version (6.4), released in April 2024, includes bug fixes, updates to smelter lists, and enhanced formatting for improved usability.

For the latest version, see our CMRT 6.6 update guide.

Who Needs to Report on Conflict Minerals?

Companies required to report on conflict minerals include:

Download our Conflict Minerals eBook to learn more about Responsible sourcing in detail.

Both regulations require companies to conduct due diligence on their supply chains and disclose the origin of their conflict minerals annually. The RMI recommends updating the CMRT at least once a year to maintain accurate and transparent supply chain data.

What Information is Required to Complete a CMRT?

The CMRT template consists of eight sheets, some of which provide instructions, while others require supplier input. The data collected falls into four main categories:

  1. Company Information:
    • Supplier details, including company name, contact information, and reporting year.
  2. Due Diligence Information:
    • Questions related to the use of 3TG minerals, regulatory applicability, and the supplier’s responsible sourcing efforts.
  3. Product List:
    • A reference to part numbers and product-level declarations.
  4. Smelter List:
    • Identification of smelters and refiners used in the supply chain, including their location and certification status.

Step-by-Step Guide to Completing the CMRT

  1. Download the Template: Access the latest CMRT version from the RMI website to ensure compliance with current standards.
  2. Gather Company Information: Compile your company’s details, including contact information and reporting year.
  3. Identify Suppliers: List all suppliers involved in the use of 3TG minerals and gather their contact information.
  4. Define Product Scope: Specify the products subject to reporting, including categories and models.
  5. Request Smelter Information: Collect details about smelters and refiners, including their name, location, and materials processed.
  6. Document Due Diligence: Ask suppliers to share information about their responsible sourcing measures, including policies, surveys, and audits.
  7. Trace Mineral Origin: Determine the countries of origin for all 3TG minerals used in your products.
  8. Validate Data: Ensure all collected information is accurate, complete, and consistent with your records.
  9. Compile Reports: Consolidate supplier data into a single CMRT submission, ready for internal or external reporting.

Here is how CMRT data flows within different stakeholders in the supply chain:

CMRT process flow.jpg

What is the Difference Between CMRT and EMRT

While the CMRT is used for reporting on 3TG minerals, the Extended Minerals Reporting Template (EMRT) focuses on other materials like cobalt and mica. Key differences include:

  • Mandatory vs. Voluntary: The CMRT is mandatory for companies under conflict minerals regulations, while the EMRT is voluntary, typically used to meet sustainability goals.
  • Minerals Covered: CMRT addresses 3TG, whereas EMRT covers extended minerals outside the conflict minerals category.

How Regilient Can Help with CMRT Reporting

The Regilient Compliance Tool simplifies conflict minerals reporting with a suite of features tailored to meet regulatory requirements:

  • Automated Data Collection: Streamline the CMRT process with automated supplier outreach and smelter risk analysis.
  • Multilingual Support: Overcome language barriers to improve supplier engagement and response rates.
  • Data Visualization: Generate exportable reports and dashboards for internal and external stakeholders.
  • Regulatory Expertise: Access guidance from in-house compliance experts to ensure accuracy and compliance with evolving regulations.
  • Scalability: Adapt to additional reporting needs, such as EMRT and STRT, as your business grows.

CMRT data gaps discovered during a customer audit or SEC review are far more costly to fix than preventing them. Book a Regilient demo to see how Regilient automates supplier engagement, validates smelter data, and keeps your conflict minerals programme audit-ready year-round.

Topics

Conflict MineralsResponsible SourcingUSA RegulationsSustainability Software

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What is the Conflict Minerals Reporting Template

What is the Conflict Minerals Reporting Template and what is it used for?
The CMRT is a standardised tool developed by the Responsible Minerals Initiative to help companies collect and disclose data on the use of tin, tungsten, tantalum, and gold (3TG) in their supply chains. It aligns with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. regilient It serves four functions: collecting supplier data on 3TG minerals, supporting compliance with Dodd-Frank Section 1502 and the EU Conflict Minerals Regulation, enabling public disclosure to investors and customers, and identifying smelters and refiners for potential RMAP audits.
Who is required to complete CMRT reporting?
Two categories of companies have direct legal obligations: US public companies manufacturing products containing 3TG, under Dodd-Frank Act Section 1502, with annual SEC disclosure requirements EU importers bringing conflict minerals into the EU from conflict-affected and high-risk areas, under EU Regulation 2017/821 Beyond these, CMRT requests cascade contractually through global supply chains. Tier 1 and Tier 2 suppliers are routinely required to complete CMRTs by their customers even when they carry no direct statutory obligation.
What smelter information must be disclosed in a CMRT?
Smelter and refiner disclosure is the most operationally demanding part of CMRT completion. Required data includes: Smelter name, country, and materials processed Certification status under the RMI's Responsible Minerals Assurance Process (RMAP) Whether minerals originate from conflict-affected or high-risk areas Follow-up documentation where smelters are unaudited or unverified Incomplete smelter data is one of the most common CMRT failure points. Downstream customers and regulators increasingly expect traceable smelter logic and documented escalation when high-risk or unknown smelters are reported.
What is the difference between CMRT and EMRT reporting?
The CMRT is focused exclusively on conflict minerals (3TG) and supports mandatory legal compliance under Dodd-Frank and the EU Conflict Minerals Regulation. The EMRT expands disclosure to materials such as cobalt and mica and is typically driven by customer ESG requirements rather than statutory mandates. regilient In practice, many manufacturers now run CMRT and EMRT workflows in parallel. The CMRT satisfies regulatory obligations; the EMRT satisfies customer sustainability expectations. Both require structured supplier engagement and annual data refresh to remain credible.
How often must CMRT data be updated to remain compliant?
The RMI recommends updating the CMRT at least once a year to maintain accurate and transparent supply chain data. In 2026, static CMRTs are considered high-risk. Companies are expected to demonstrate continuous due diligence, supplier engagement, and escalation when smelter or sourcing data changes. regilient Annual updates are the minimum. Best practice for companies with complex supply chains is a rolling review triggered by supplier changes, smelter status updates from RMAP, or new CMRT version releases from the RMI.
How does Regilient help manufacturers manage CMRT reporting at scale?
Regilient's agentic sustainability platform automates CMRT compliance across five areas: Automated supplier outreach and CMRT data collection with multilingual support to improve response rates across global supply chains Smelter risk analysis cross-referenced against the RMAP certified smelter list in real time Data validation to flag incomplete, outdated, or inconsistent smelter disclosures before submission Parallel EMRT and AMRT workflow support for manufacturers running multiple minerals reporting programmes simultaneously Exportable dashboards and audit-ready documentation for SEC filings, EU regulatory disclosures, and customer audits