Table of Contents
- RCOI Process: How to Conduct a Reasonable Country of Origin Inquiry
- What Is the RCOI Process?
- RCOI vs. CMRT: What Is the Difference?
- Step 1: Define the RCOI Scope
- Step 2: Identify Relevant Suppliers
- Step 3: Collect Supplier Information
- Step 4: Review Supplier Responses
- Step 5: Evaluate Smelter and Refiner Information
- Step 6: Investigate RCOI Red Flags
- Step 7: Document the RCOI
- What Happens After the RCOI?
- RCOI Process Checklist
- Common RCOI Mistakes
- Treating the CMRT as the RCOI
- Accepting every supplier response without validation
- Relying only on a "conflict-free" declaration
- Failing to document follow-ups
- Treating RCOI as a once-a-year spreadsheet exercise
- RCOI Is a Process, Not a Form
RCOI Process: How to Conduct a Reasonable Country of Origin Inquiry
A Reasonable Country of Origin Inquiry (RCOI) is the process a company uses to determine whether the 3TG minerals in its products may have originated in the Democratic Republic of the Congo (DRC) or an adjoining country, or whether they came from recycled or scrap sources, where the U.S. conflict minerals rule applies.
RCOI is an important step in the conflict minerals reporting process, but it is not the same as completing a CMRT.
The CMRT is a standardized tool for collecting supply-chain information. RCOI is the broader inquiry used to evaluate that information and reach a country-of-origin determination. The SEC requires an RCOI to be conducted in good faith and reasonably designed to make that determination.
What Is the RCOI Process?
For a company subject to the SEC conflict minerals rule, the process can be summarized as:
Determine scope → Identify relevant suppliers → Collect information → Evaluate country of origin → Review smelters/refiners → Investigate gaps → Document the conclusion → Determine next steps
The purpose is not simply to obtain a supplier declaration saying that minerals are "conflict free."
The inquiry needs to provide a reasonable basis for determining whether the minerals originated in the covered countries or came from recycled or scrap sources.
RCOI vs. CMRT: What Is the Difference?
The two are closely connected, but they serve different purposes.
RCOI | CMRT |
|---|---|
Compliance inquiry/process | Standardized reporting template |
Used to determine country of origin | Used to collect supplier information |
Evaluates information and evidence | Provides structured supplier declarations |
Can involve follow-up investigation | Provides information for that investigation |
Supports the company's reporting determination | Supports supply-chain data collection |
The RMI recommends using the CMRT or an equivalent to help identify smelters and refiners rather than relying only on a simple supplier declaration.
Step 1: Define the RCOI Scope
Before contacting suppliers, establish what the inquiry needs to cover.
For companies subject to the SEC rule, the starting point is determining whether they manufacture or contract to manufacture products in which conflict minerals are necessary to the functionality or production of the product.
The company should then identify:
- Products within scope
- Relevant components and materials
- Suppliers associated with those products
- 3TG that may be present
- Applicable reporting period
- Information required from suppliers
This scope determines who needs to participate in the RCOI.
Step 2: Identify Relevant Suppliers
Supplier identification is often one of the most difficult operational parts of the process.
A company may know its Tier 1 supplier but have limited visibility into the smelter or refiner further upstream.
The objective is therefore not simply to ask every supplier the same question.
Companies should identify suppliers and products where 3TG may be necessary to product functionality or production and prioritize the supply-chain relationships that can provide relevant information.
For large supplier populations, this requires a controlled process for:
- Supplier identification
- Supplier segmentation
- Outreach
- Response tracking
- Escalation
Step 3: Collect Supplier Information
Once suppliers have been identified, the company can request the information needed for the inquiry.
The CMRT is commonly used for this purpose.
The RMI provides standardized reporting templates specifically to facilitate the transfer of information about mineral country of origin and smelters and refiners in the supply chain. (Responsible Minerals Initiative)
Supplier outreach should clearly communicate:
- Why the information is required
- Products or components in scope
- Applicable reporting period
- Required template
- Submission deadline
- Supporting information required
Simply sending the CMRT and waiting for responses is rarely enough for a large supplier population.
Non-responses and incomplete submissions need to be tracked and followed up.
For the detailed template process, see How to Complete a CMRT.
Step 4: Review Supplier Responses
A submitted CMRT should not automatically be treated as a completed RCOI.
The response needs to be reviewed for:
- Completeness
- Reporting scope
- 3TG declarations
- Smelter/refiner information
- Country-of-origin information
- Inconsistent responses
- Missing information
- Outdated information
For example, a supplier may submit a CMRT but fail to identify the relevant smelters and refiners.
That creates an information gap that may require additional supplier engagement.
See CMRT Reporting Template for the information collected through the template.
Step 5: Evaluate Smelter and Refiner Information
Smelters and refiners are a critical point in the 3TG supply chain.
RMI notes that downstream companies may have difficulty obtaining specific country-of-origin information and recommends using the CMRT or equivalent to identify smelters and refiners.
The company should review the facilities identified by suppliers and investigate:
- Unknown facilities
- Incomplete facility names
- Incorrect facility identifiers
- Facilities that cannot be matched to reference information
- Relevant assurance or audit status
RMI also provides country-of-origin information for qualifying conformant smelters and refiners through its RCOI data resource.
For the detailed facility-validation process, see CMRT Smelter Validation: Conflict Minerals Compliance Gaps.
Step 6: Investigate RCOI Red Flags
Not every supplier response will provide enough information to reach a clear conclusion.
Common issues include:
- Supplier does not respond
- CMRT is incomplete
- Supplier provides outdated information
- Supplier cannot identify its smelters or refiners
- Facility information cannot be matched
- Country-of-origin information is unavailable
- Supplier responses contain inconsistencies
- Previous-year information has been copied without confirmation
These issues should be documented and investigated according to the company's RCOI procedures.
A weak RCOI process is not simply one with a low response rate. The bigger issue is failing to identify, investigate and document material information gaps.
Step 7: Document the RCOI
Documentation is an important part of demonstrating how the inquiry was performed.
Maintain records of:
- Suppliers included in the inquiry
- Products or components considered
- CMRT requests
- Supplier responses
- Follow-up communications
- Validation activities
- Identified smelters and refiners
- Exceptions and unresolved gaps
- Additional investigations
- Final country-of-origin determination
The SEC requires companies to provide a brief description of the RCOI undertaken and its results when the applicable reporting outcome does not require a Conflict Minerals Report. (SEC)
The documentation should therefore allow the company to explain what it asked, what it received, what it evaluated and how it reached its conclusion.
What Happens After the RCOI?
The result of the RCOI determines the next step under the SEC conflict minerals framework.
If the company determines that the minerals did not originate in the covered countries, or that they came from recycled or scrap sources, or has no reason to believe they may have originated in the covered countries or may not be recycled/scrap, the reporting requirements differ from a situation where the company knows or has reason to believe the minerals may have originated in the covered countries.
Where the RCOI indicates that the minerals may have originated in the covered countries and may not be from recycled or scrap sources, the company proceeds to the applicable due diligence stage.
This is why RCOI should be treated as a defined stage in the compliance process rather than as a supplier questionnaire exercise.
RCOI Process Checklist
Before closing the RCOI, confirm that you have:
Common RCOI Mistakes
Treating the CMRT as the RCOI
A CMRT provides standardized supplier information. It does not eliminate the need to evaluate that information.
Accepting every supplier response without validation
A completed template can still contain incomplete, inconsistent or outdated information.
Relying only on a "conflict-free" declaration
RMI recommends using the CMRT or equivalent to identify smelters and refiners; a simple non-use declaration may not provide sufficient information for the broader inquiry and due diligence.
Failing to document follow-ups
If suppliers do not respond or provide incomplete information, retain evidence of the outreach and escalation performed.
Treating RCOI as a once-a-year spreadsheet exercise
The reporting may be annual, but the underlying supplier information and supply-chain risks can change.
RCOI Is a Process, Not a Form
The CMRT gives companies a standardized way to collect 3TG supply-chain information.
RCOI is what the company does with that information.
The operational process is:
Scope → Supplier outreach → CMRT collection → Validation → Investigation → Country-of-origin determination → Documentation → Due diligence, where required
For companies managing hundreds or thousands of suppliers, maintaining this process through spreadsheets and email can make response tracking, escalation, validation and evidence management difficult.
A centralized CMRT compliance software workflow can bring supplier campaigns, CMRT collection, validation, response tracking and reporting evidence into one process.