RCOI (Reasonable Country of Origin Inquiry)

A Reasonable Country of Origin Inquiry (RCOI) is the initial due diligence step required of SEC registrants under Dodd-Frank Section 1502. An RCOI is a good-faith inquiry into whether a company’s conflict minerals originated in the DRC or adjoining countries. The RCOI uses supplier declarations (typically CMRT data) to establish likely country of origin. If the RCOI reasonably determines that minerals did not originate from covered countries, or originated from scrap/recycled sources, a Conflict Minerals Report may not be required.

Dodd-Frank Act Section 1502; SEC Rule 13p-1; Exchange Act Release No. 34-67716 (August 22, 2012), pages 60–74.

The RCOI is distinct from full due diligence. It is a threshold inquiry: if an RCOI concludes that conflict minerals did not come from the DRC or adjoining countries (or came from recycled/scrap), the company files a simpler Form SD without a Conflict Minerals Report. If the RCOI cannot make this determination — which is common for most manufacturers — full due diligence and a CMR are required. The CMRT is the primary tool used to collect RCOI data from suppliers.

A machinery manufacturer collects CMRT responses from 350 suppliers. The RCOI shows that 2 tin smelters identified in the supply chain source from high-risk areas. Since the RCOI cannot exclude DRC or adjoining country origin, the manufacturer conducts full OECD-aligned due diligence and files a Conflict Minerals Report with its Form SD.