Table of Contents
- What Is the CMRT?
- What Is the CMRT Used For?
- Who Needs to Complete a CMRT?
- U.S. conflict minerals reporting
- EU conflict minerals due diligence
- Customer-driven reporting
- What Information Does the CMRT Collect?
- 1. Company information
- 2. Product and scope information
- 3. 3TG information
- 4. Smelter and refiner information
- 5. Country-of-origin information
- 6. Due-diligence information
- What Is the Latest CMRT Version?
- CMRT vs. EMRT vs. AMRT
- How Does CMRT Reporting Work?
- 1. Define the reporting scope
- 2. Identify suppliers
- 3. Send CMRT requests
- 4. Collect supplier declarations
- 5. Validate responses
- 6. Review smelter information
- 7. Consolidate supplier data
- 8. Resolve exceptions
- 9. Maintain evidence
- How to Complete a CMRT
- What Are Common CMRT Reporting Problems?
- Incomplete supplier responses
- Outdated templates
- Inconsistent company information
- Missing smelter information
- Poor follow-up visibility
- Manual consolidation
- CMRT Smelter Validation
- CMRT and Conflict Minerals Due Diligence
- CMRT Compliance: Spreadsheet or Automated Workflow?
- Download the Conflict Minerals Reporting Guide
- CMRT Reporting Checklist
The Conflict Minerals Reporting Template (CMRT) is a standardized reporting tool used to collect information about tin, tantalum, tungsten, and gold (3TG) in global supply chains. Developed and maintained by the Responsible Minerals Initiative (RMI), the CMRT helps companies collect supplier declarations, identify smelters and refiners, assess country-of-origin information, and support conflict minerals due diligence.
For manufacturers and suppliers, CMRT reporting is more than completing a spreadsheet. The process involves defining reporting scope, engaging suppliers, validating declarations, reviewing smelter information, resolving data gaps, and maintaining evidence that can support customer, regulatory, and audit requirements.
What Is the CMRT?
The Conflict Minerals Reporting Template (CMRT) is a standardized questionnaire developed by the RMI to facilitate the transfer of information about 3TG minerals through the supply chain.
The four minerals covered by the CMRT are:
- Tin
- Tantalum
- Tungsten
- Gold
The CMRT is commonly used by manufacturers, suppliers, distributors, and other companies that need to understand whether 3TG in their products or supply chains may originate from conflict-affected and high-risk areas (CAHRAs).
The template supports several activities:
- Collecting supplier declarations
- Identifying smelters and refiners
- Assessing countries of origin
- Supporting conflict-minerals due diligence
- Communicating sourcing information to customers
- Maintaining evidence for compliance programs
- Supporting regulatory and customer reporting
The RMI provides standardized mineral reporting templates specifically to facilitate the transfer of country-of-origin and smelter/refiner information through supply chains. check details here - oldp4.responsiblemineralsinitiative.org
What Is the CMRT Used For?
The CMRT is primarily used to establish supply-chain visibility around 3TG.
A typical CMRT process helps a company answer questions such as:
- Does the supplier use tin, tantalum, tungsten, or gold?
- Which products or product groups contain 3TG?
- Which smelters or refiners are involved?
- What countries of origin are associated with the minerals?
- Are suppliers conducting relevant due diligence?
- Are identified smelters participating in recognized assurance programs?
- What information requires additional investigation?
This makes the CMRT particularly useful when a company needs to consolidate information from a large supplier base rather than manage individual declarations manually.
Who Needs to Complete a CMRT?
CMRT completion can arise from regulatory obligations, customer requirements, procurement requirements, or internal responsible-sourcing programs.
U.S. conflict minerals reporting
U.S. publicly traded companies can have conflict-minerals disclosure obligations under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act.
Even when a supplier does not have a direct SEC reporting obligation, it may receive a CMRT request from a customer that does.
EU conflict minerals due diligence
The EU Conflict Minerals Regulation (EU) 2017/821 establishes due-diligence obligations for certain EU importers of tin, tantalum, tungsten and gold.
Again, companies outside the direct scope may still encounter CMRT requests from customers seeking supply-chain information.
Customer-driven reporting
In practice, CMRT requests often move downstream through the supply chain.
A manufacturer may request a CMRT from a Tier-1 supplier. That supplier may then need to collect information from its own suppliers.
This creates a cascading data-collection process:
Customer → Tier-1 supplier → Tier-2 supplier → Smelter/refiner information
That is why CMRT management becomes difficult when it is handled entirely through email and spreadsheets.
What Information Does the CMRT Collect?
CMRT reporting generally brings together several types of supply-chain information.
1. Company information
This identifies the reporting organization and establishes the context of the declaration.
2. Product and scope information
Companies need to identify the products, product groups, or supply-chain scope covered by the declaration.
3. 3TG information
The CMRT establishes whether tin, tantalum, tungsten, or gold are present within the relevant supply chain.
4. Smelter and refiner information
The reporting process can require information about the smelters and refiners associated with the minerals.
5. Country-of-origin information
Companies use the collected information to understand where relevant minerals originate and whether additional due diligence is required.
6. Due-diligence information
Supplier responses can provide information about sourcing policies, due-diligence practices, and other responsible-sourcing controls.
What Is the Latest CMRT Version?
This is an area that requires particular care because CMRT versions change over time.
The current page previously stated that CMRT 6.4 was the latest version. That is outdated.
The RMI states that the latest versions of the CMRT, EMRT and AMRT with functional changes were released on April 17, 2026. RMI also states that versions without RMI logos and branding were released on August 19, 2026, and that these are functionally identical to the April versions.
Therefore, companies should verify the current CMRT version directly with RMI before launching a supplier survey.
RMI also advises companies to use the most recent version available when they initiate their annual survey and to specify which version they used or allowed when collecting supplier information. (Responsible Minerals Initiative)
For a detailed breakdown, see:
CMRT 6.6: What Suppliers Need to Know
CMRT vs. EMRT vs. AMRT
The three RMI mineral reporting templates serve different mineral scopes.
Template | Primary scope |
|---|---|
CMRT | Tin, tantalum, tungsten and gold (3TG) |
EMRT | Extended minerals covered by the current RMI EMRT |
AMRT | Additional minerals not covered by CMRT or EMRT |
The RMI describes CMRT as the template for 3TG, EMRT as the template for its extended mineral scope, and AMRT as a template whose mineral scope is determined by the user.
For the detailed comparison, see:
CMRT vs. EMRT vs. AMRT: What's the Difference?
How Does CMRT Reporting Work?
A practical CMRT program usually follows this workflow:
1. Define the reporting scope
Determine which products, suppliers, business units, or reporting populations are included.
2. Identify suppliers
Build the supplier population that needs to provide conflict-minerals information.
3. Send CMRT requests
Distribute the appropriate CMRT version and establish response deadlines.
4. Collect supplier declarations
Gather completed CMRT files and supporting information.
5. Validate responses
Check for:
- Missing fields
- Incorrect template versions
- Inconsistent answers
- Incomplete supplier information
- Missing smelters or refiners
- Duplicate or inconsistent company data
6. Review smelter information
Compare reported smelters and refiners against relevant RMI reference information and investigate questionable or incomplete records.
For detailed guidance, see:
How to Validate Smelters in a CMRT: RMI & RMAP Guide
7. Consolidate supplier data
Aggregate validated responses so the organization can understand its overall 3TG sourcing profile.
8. Resolve exceptions
Follow up with suppliers where information is missing, inconsistent, outdated, or requires additional evidence.
9. Maintain evidence
Keep the completed declarations, supplier communications, validation records, and escalation history needed to demonstrate the due-diligence process.
How to Complete a CMRT
Completing a CMRT requires more than filling in company information.
A typical process includes:
- Obtain the applicable current CMRT version.
- Define the products and suppliers within scope.
- Collect relevant supplier information.
- Determine whether 3TG is present.
- Collect smelter and refiner information.
- Review country-of-origin information.
- Assess supplier due-diligence responses.
- Validate the completed declaration.
- Resolve incomplete or inconsistent answers.
- Consolidate the results and retain supporting evidence.
For the detailed step-by-step process, use the dedicated cluster article:
Guidelines for Successfully Completing CMRT
This separation is intentional: this pillar explains what CMRT reporting is and how the ecosystem works; the cluster article owns the detailed completion process.
What Are Common CMRT Reporting Problems?
The biggest operational challenges usually occur after the CMRT has been sent to suppliers.
Common issues include:
Incomplete supplier responses
Suppliers may leave questions unanswered or provide insufficient information.
Outdated templates
Different suppliers may return different CMRT versions, making consolidation difficult.
Inconsistent company information
Supplier names, addresses, identifiers, and product information may vary between submissions.
Missing smelter information
A declaration may identify minerals without providing enough information to validate the associated smelters or refiners.
Poor follow-up visibility
When supplier requests are managed through email, compliance teams can lose track of who responded, who needs follow-up, and which declarations require review.
Manual consolidation
Combining hundreds of spreadsheets increases the risk of duplicate records, version errors and inconsistent reporting.
CMRT Smelter Validation
Smelter and refiner data is one of the most important parts of a defensible CMRT program.
A company should be able to determine:
- Which smelters and refiners suppliers reported
- Whether identifiers are complete
- Whether the entities can be matched to reference data
- Whether their assurance status requires further review
- Which suppliers require clarification or escalation
This is where a structured validation process becomes more useful than simply storing completed CMRT spreadsheets.
For the detailed process:
Validate Smelters in CMRT: RMI, RMAP & Red Flags
CMRT and Conflict Minerals Due Diligence
The CMRT is an important data-collection mechanism, but completing a CMRT does not by itself constitute an entire conflict-minerals due-diligence program.
A mature program also needs to consider:
- Supply-chain risk identification
- Supplier engagement
- Country-of-origin information
- Smelter/refiner validation
- Risk escalation
- Corrective actions
- Documentation
- Periodic reassessment
- Reporting and evidence retention
The broader reporting process is covered in:
Conflict Minerals Reporting Process
CMRT Compliance: Spreadsheet or Automated Workflow?
For a small supplier population, spreadsheet-based CMRT collection may be manageable.
At scale, the process becomes more complicated.
A compliance team may need to manage:
- Hundreds or thousands of suppliers
- Multiple CMRT versions
- Different response dates
- Automated reminders
- Supplier questions
- Validation rules
- Smelter matching
- Exceptions
- Historical declarations
- Consolidated reporting
- Audit evidence
This is where CMRT compliance software can reduce manual work.
Regilient can support the workflow through automated supplier outreach, multilingual communication, CMRT collection, validation, smelter normalization, reporting, and audit-ready records.
Explore Regilient's CMRT Compliance Software
Download the Conflict Minerals Reporting Guide
If you are building or improving a conflict-minerals program, the Conflict Minerals Reporting eBook provides a deeper reference for CMRT reporting, supplier due diligence, and responsible sourcing.
Download the Conflict Minerals Reporting eBook
Use the eBook as the next step for readers who need a more comprehensive implementation guide rather than immediately moving them to a product page.
CMRT Reporting Checklist
Before closing a CMRT reporting cycle, confirm that you have:
