Why EMRT and AMRT Requests Are Rising Even Without a Regulation Mandate

Nobody is legally required to fill these out. So why are so many customers asking? 

The Conflict Minerals Reporting Template has a clear legal anchor: Dodd-Frank Section 1502 for US-listed companies, the EU Conflict Minerals Regulation for EU importers. If a customer sends you a CMRT, you know why.

The Extended Minerals Reporting Template and the Additional Minerals Reporting Template are different. No regulation explicitly requires a company to complete an EMRT or AMRT. There is no SEC filing that references them. There is no EU regulation that names them as a compliance mechanism. And yet EMRT and AMRT requests from OEM customers have surged over the past 18 months, particularly in automotive, electronics, battery manufacturing, and aerospace.

On April 17, 2026, the Responsible Minerals Initiative released updated versions of all three templates simultaneously: CMRT 6.6, EMRT 2.11, and AMRT 1.31. The fact that RMI now maintains and updates these three templates in lockstep signals that extended and additional minerals reporting is no longer a voluntary add-on. It's becoming part of the standard responsible minerals programme.

This article explains what's driving the rise in EMRT and AMRT requests, what the latest template versions include, and why manufacturers who treat these as optional are falling behind customer and regulatory expectations.

What is EMRT and AMRT Cover (and How They Differ from the CMRT)

CMRT: 3TG minerals (tin, tantalum, tungsten, gold)

The CMRT is the original template, designed for conflict minerals due diligence under Dodd-Frank and the EU CMR. It covers four minerals (3TG) and focuses on smelter and refiner identification for these metals. Current version: 6.6 (April 17, 2026).

EMRT: six extended minerals (cobalt, mica, copper, natural graphite, lithium, nickel)

The EMRT was launched in October 2021, initially covering cobalt and mica. In April 2025, RMI expanded it with EMRT 2.0 to include four additional minerals: copper, natural graphite, lithium, and nickel. This expansion directly supports companies preparing for the EU Battery Regulation, which requires due diligence on cobalt, lithium, nickel, and natural graphite in battery supply chains. Current version: 2.11 (April 17, 2026).

The EMRT includes a Smelter Reference List (or "Smelter Look-up") containing pinch point facilities identified by RMI for each mineral in scope. This makes it functionally similar to the CMRT: suppliers identify which processors are in their supply chain, and downstream companies validate those facilities against RMI's database.

AMRT: user-defined minerals (up to ten, chosen by the requester)

The AMRT (originally the Pilot Reporting Template, rebranded in November 2022) covers minerals not included in the CMRT or EMRT. The requester defines which minerals are in scope, up to a maximum of ten. Common use cases include reporting on bauxite, manganese, rare earth elements, titanium, chromium, zinc, and other minerals flagged by customer ESG programmes or regulatory risk assessments.

Unlike the CMRT and EMRT, the AMRT was not originally designed with a fixed Smelter Look-up tab. However, AMRT 1.3 (released October 2025) added a Smelter Look-up tab containing a standard smelter list for all minerals in scope, bringing the AMRT closer to the CMRT/EMRT model. Current version: 1.31 (1.31 is a minor revision of 1.3) (April 17, 2026).

Five Forces Driving the Surge in EMRT and AMRT Requests

1. The EU Battery Regulation requires due diligence on cobalt, lithium, nickel, and natural graphite

This is the single biggest driver. The EU Battery Regulation (2023/1542) requires manufacturers and economic operators to adopt supply chain due diligence policies for cobalt, natural graphite, lithium, and nickel. While enforcement of the due diligence obligations was postponed to August 18, 2027 following the EU's 2025 regulatory simplification, the preparation window is active now.

The EMRT is the most widely adopted industry tool for collecting cobalt, lithium, nickel, and graphite supply chain data. OEMs in the automotive and battery manufacturing sectors are issuing EMRT requests to their suppliers today, not because the regulation is in force, but because the data needed to comply takes years to collect through multi-tier supply chains. Companies that wait for the August 2027 enforcement date to start collecting will find themselves unable to produce the required due diligence evidence in time.

2. ESG investor and customer pressure on cobalt and mica sourcing

Cobalt and mica supply chains have been under intense ESG scrutiny since well before the EMRT existed. Cobalt mining in the DRC (which supplies approximately 70 to 75% of the world's cobalt) is associated with artisanal mining, child labour, and environmental degradation. Mica sourcing from India and Madagascar faces similar human rights concerns.

For companies in electronics, consumer goods, and energy storage, demonstrating due diligence on cobalt and mica sourcing is now a standard ESG reporting expectation. EMRT data provides the structured, standardised evidence that ESG auditors and investors are looking for. Companies that cannot produce EMRT data when requested are flagged as supply chain transparency gaps.

3. The UFLPA is expanding beyond 3TG into extended minerals

The Uyghur Forced Labor Prevention Act's enforcement has expanded significantly beyond its original focus on apparel, cotton, and polysilicon. DHS's August 2025 strategy update prioritised lithium, copper, steel, PVC, and aluminium for FY2026 enforcement. In FY2025, CBP stopped 7,325 shipments for UFLPA review.

For minerals like lithium and copper (both now covered by the EMRT), UFLPA exposure requires companies to trace sourcing to the processor level and demonstrate that no forced labour is involved. The EMRT provides a standardised mechanism for collecting this data from suppliers. Companies that only track 3TG through the CMRT have a blind spot on these extended minerals.

4. OEM customers are cascading their own due diligence requirements downstream

Automotive OEMs like Schaeffler, BMW, and major electronics manufacturers are not waiting for regulations to take effect. They are issuing EMRT and AMRT requests to their supply chains as part of their own corporate due diligence programmes, ESG commitments, and customer-facing sustainability reports.

This creates a cascade effect: an OEM requests EMRT data from its Tier-1 suppliers, who in turn must request it from their Tier-2 suppliers, and so on. The supplier who cannot respond to an EMRT request loses credibility (and potentially business) regardless of whether any regulation mandates the disclosure.

5. RMI's template evolution signals that extended minerals are becoming permanent scope

The trajectory is clear. EMRT launched in 2021 with two minerals. EMRT 2.0 in April 2025 expanded to six minerals. EMRT 2.11 in April 2026 refined data accuracy and compatibility. RMI has stated its intention to continue adding minerals to the EMRT over time, and the AMRT exists specifically to bridge the gap until minerals are formally incorporated.

RMI now releases all three templates (CMRT, EMRT, AMRT) on the same date, with the same version cadence, and recommends all three for the current reporting year. This synchronised release cycle signals that extended and additional minerals reporting is no longer a pilot programme. It's a permanent component of responsible minerals compliance.

What Changed in EMRT 2.11 and AMRT 1.31

EMRT 2.11

EMRT 2.11 focuses on data accuracy and standards compatibility:

• Updated ISO short names for countries, states, and provinces (reducing validation errors)
• Bug fixes including resolution of the date entry issue in the Declaration tab
• Continued alignment with the IPC-1755 Responsible Sourcing of Minerals Data Exchange Standard
• Updated Smelter Reference List reflecting the latest RMI processor data for all six minerals

RMI recommends EMRT 2.11 for the current reporting year. The next EMRT version is anticipated in Spring 2027.

AMRT 1.31

AMRT 1.31 includes:

• Updated ISO short names for countries, states, and provinces
• Minor data corrections and usability improvements
• Continued support for user-defined mineral scope (up to ten minerals)

The next AMRT version is anticipated for Fall 2026.

Template transition guidance

Companies still collecting EMRT data on version 2.0 or 2.1 and AMRT data on version 1.2 or 1.3 should transition to the latest versions. Prior-version submissions do not include the updated smelter reference data and ISO corrections introduced in 2.11 and 1.31. RMI recommends using the current version for all new data collection.

Why "Not Legally Required" Is No Longer a Valid Reason to Ignore EMRT/AMRT

The most common reason companies give for not responding to EMRT or AMRT requests is that the templates are not legally required. This was a defensible position in 2022. It is increasingly indefensible in 2026, for three reasons:

The EU Battery Regulation's due diligence obligations are enforceable from August 2027. The EMRT is the de facto industry tool for collecting the required cobalt, lithium, nickel, and graphite data. Companies that haven't collected EMRT data by mid-2027 will have no mechanism to demonstrate compliance.

OEM customers treat non-response as a risk signal. A supplier who declines to complete an EMRT is indistinguishable, from the customer's perspective, from a supplier who has something to hide. In a procurement environment where responsible sourcing is a qualification criterion, non-response is a competitive disadvantage.

The UFLPA applies now, not in 2027. For lithium and copper, UFLPA enforcement is already active. Companies importing articles containing these minerals into the US need processor-level traceability today. The EMRT provides it; a blank response does not.

A Self-Check for Your Extended Minerals Programme

Six questions to assess your readiness:

• Template coverage: Am I collecting EMRT and AMRT data from my suppliers, or only CMRTs?
• Template version: Am I collecting on EMRT 2.11 and AMRT 1.31 (released April 17, 2026), or on older versions with outdated processor reference data?
• Mineral scope: Have I identified which of the six EMRT minerals (cobalt, mica, copper, graphite, lithium, nickel) are present in my products, and am I collecting supply chain data for each?
• Battery Regulation preparedness: If I manufacture or import batteries into the EU, have I started collecting cobalt, lithium, nickel, and graphite due diligence data through EMRT, or am I waiting for the August 2027 enforcement date?
• UFLPA exposure: For products containing lithium or copper, can I trace sourcing to the processor level and demonstrate compliance with UFLPA requirements?
• Customer response rate: What percentage of my suppliers respond to EMRT and AMRT requests, and what is my escalation process for non-responders?

If more than two answers reveal gaps, your extended minerals programme is behind customer and regulatory expectations.

Where Regilient fits in

Extended and additional minerals reporting adds complexity on top of an already demanding conflict minerals programme. Suppliers receiving CMRT, EMRT, and AMRT requests simultaneously face survey fatigue. Compliance teams consolidating data across three templates, six EMRT minerals, and user-defined AMRT minerals face a data management challenge that spreadsheets cannot handle.

Regilient's agentic sustainability platform automates extended minerals compliance at the scale required:

• Unified CMRT, EMRT, and AMRT collection through a single supplier engagement workflow, reducing survey fatigue and improving response rates
• Processor validation against RMI's Smelter Reference Lists for all three templates, with real-time status monitoring
• EU Battery Regulation alignment that maps EMRT data (cobalt, lithium, nickel, graphite) against due diligence obligations, preparing companies for August 2027 enforcement
• UFLPA screening for extended minerals (lithium, copper) with processor-level traceability and Entity List cross-referencing
• Template version management that ensures all suppliers are reporting on current versions (CMRT 6.6, EMRT 2.11, AMRT 1.31) with the latest processor reference data

The era of treating EMRT and AMRT as voluntary add-ons to a 3TG programme is ending. Customer expectations, EU Battery Regulation timelines, and UFLPA enforcement are converging on the same conclusion: extended minerals due diligence is no longer optional. The companies that built the infrastructure for it in 2026 will be ready when enforcement arrives. The companies that waited will be starting from zero.

Book a Regilient demo to see how agentic extended minerals compliance unifies CMRT, EMRT, and AMRT data collection across your entire supply chain.

Regilient provides agentic sustainability software for product compliance, supplier engagement, and regulatory intelligence across REACH, RoHS, PFAS, CMRT, SCIP, and global chemical regulations.