Smelter/Refiner

A smelter or refiner is the facility that processes raw 3TG mineral ores into metal products. In conflict minerals supply chains, smelters and refiners are the ‘pinch point’ — the last stage where mineral origin can be verified before transformation makes individual source traceability impossible. The four mineral types have specific smelting processes: tin smelters process cassiterite ore, tantalum processors convert coltan into tantalum powder, tungsten smelters process wolframite/scheelite, and gold refiners process gold doré or scrap. RMAP audits are conducted at the smelter/refiner level.

Dodd-Frank Act Section 1502; Regulation (EU) 2017/821; RMI RMAP documentation; OECD Due Diligence Guidance.

Identifying all smelters and refiners in your supply chain is the most critical step in conflict minerals compliance. The CMRT is designed specifically to collect this information from suppliers. Once identified, each smelter’s RMAP status must be verified. Smelters not on the RMAP conformant or active list are non-conformant and represent a risk that must be addressed through engagement or supply chain changes. The Standard Smelter List in CMRT 6.6 contains the current verified facility data.

A capacitor manufacturer identifies through CMRT collection that its tantalum supply chain passes through 6 tantalum processors worldwide. It verifies 5 are RMAP conformant and 1 is listed as active (audit in progress). The manufacturer engages the active processor to ensure it progresses to conformant status and documents this engagement in its Conflict Minerals Report.