Understanding the Additional Minerals Reporting Template (AMRT)
The Additional Minerals Reporting Template (AMRT) is a free, standardized tool designed to help businesses collect essential due diligence data on minerals beyond conflict minerals (3TG) and extended minerals (cobalt and mica). Unlike these minerals, which have their own specific reporting templates, the AMRT provides a broader framework for tracking various minerals of concern. Developed by the Responsible Minerals Initiative (RMI), the AMRT enhances supply chain transparency, enabling companies to meet ethical and regulatory standards while ensuring responsible sourcing practices. Originally introduced as the Pilot Reporting Template (PRT) over two years ago, the tool has now evolved beyond its initial phase and has been officially rebranded as AMRT 1.2. What Makes AMRT Unique? The AMRT is a versatile reporting tool that is not limited to specific minerals. Instead, it allows businesses to track up to ten minerals of concern within a single template. This flexibility enables users to define the scope based on their unique supply chain needs. How Does AMRT Differ from CMRT and EMRT? Although the AMRT, Conflict Minerals Reporting Template (CMRT), and Extended Minerals Reporting Template (EMRT) share similarities, they serve distinct purposes: Challenges in AMRT Adoption Despite its benefits, companies face several challenges in implementing the AMRT: Solutions for Effective AMRT Implementation To address these challenges, companies can take proactive steps: Applications of AMRT The AMRT plays a crucial role in ensuring ethical and responsible sourcing by: At ComplianceXL, we offer AMRT regulatory compliance services to help companies collect and manage AMRT data for their products. Our compliance data management approach ensures that supplier certificates and declarations remain updated. Additionally, we provide ongoing maintenance services to validate and preserve regulatory documents, ensuring their accuracy and compliance with industry standards. FAQs: 1. Which minerals are covered by the AMRT? The AMRT primarily focuses on minerals that do not fall under the traditional 3TG category but still present ethical or sourcing concerns. This includes minerals like cobalt, mica, and others essential to various industries. 2. How can I access the AMRT? The AMRT is available for free on the Responsible Minerals Initiative (RMI) website. Companies can download the template and begin using it to report their due diligence information. By leveraging the AMRT, businesses can strengthen their commitment to ethical sourcing, regulatory compliance, and supply chain transparency.
What’s New with the Extended Minerals Reporting Template (EMRT)
The Extended Minerals Reporting Template (EMRT), developed by the Responsible Minerals Initiative (RMI), is a standardized tool for companies to collect and report data on minerals used in their supply chains. Like the Conflict Minerals Reporting Template (CMRT), which focuses on the 3TG minerals—Tantalum, Tin, Tungsten, and Gold—the EMRT is specifically designed for reporting on Cobalt and Mica. The EMRT is instrumental in promoting transparency, traceability, and responsible sourcing across supply chains. By leveraging this tool, companies can identify potential risks and implement practices to mitigate them, ensuring ethical mineral sourcing. What’s New in EMRT Version 1.2? The RMI regularly updates the EMRT to enhance its functionality and align with the latest standards. The most recent update, EMRT v1.2, was released on May 12, 2023, and includes: It’s worth noting that the Cobalt Reporting Template (CRT) and Mica Reporting Template (MRT), previously used for reporting these minerals, were officially phased out by RMI on March 31, 2022. Companies are now required to use EMRT v1.2 or later for their mineral reporting to stay compliant with RMI’s guidelines. How to Use the EMRT While the RMI provides the EMRT, it does not collect submissions directly. Companies are responsible for: Keeping up with the latest EMRT requirements is crucial for maintaining compliance and promoting responsible sourcing. By adopting EMRT v1.2, companies demonstrate their commitment to ethical practices while reducing risks linked to high-risk smelters. At ComplianceXL, we support companies in sourcing and validating Cobalt and Mica data in alignment with EMRT requirements. Our services include: We help businesses navigate the complexities of responsible mineral sourcing, empowering them to build resilient and ethical supply chains.
Understanding CMRT 6.4: A Guide to Responsible Mineral Sourcing
The Conflict Minerals Reporting Template (CMRT) plays a pivotal role in enabling companies to uphold responsible mineral sourcing practices throughout their supply chains. With the debut of CMRT 6.4, organizations gain access to refined reporting standards and advanced functionalities tailored to bolster transparency and accountability. In this article, we’ll delve into the significance of CMRT 6.4, highlighting its key enhancements and how businesses can harness its capabilities to advance ethical mineral procurement initiatives. Developed by the Responsible Minerals Initiative (RMI), the CMRT serves as a uniform reporting framework facilitating the collection and disclosure of data concerning the origins and presence of conflict minerals, such as gold, tin, tantalum, and tungsten, sourced from regions rife with armed conflict and human rights violations. What’s New in CMRT 6.4: CMRT 6.4 released on April 26th, 2024, and introduces several updates and improvements to enhance the effectiveness and reliability of mineral reporting. Key features of CMRT 6.4 include: Benefits of CMRT 6.4 Adoption: Adopting CMRT 6.4 offers several benefits for companies committed to responsible mineral sourcing: Implementing CMRT 6.4: To effectively implement CMRT 6.4, companies can follow these steps: CMRT 6.4 represents a significant milestone in the journey towards responsible mineral sourcing and supply chain transparency. By embracing CMRT 6.4 and committing to ethical procurement practices, companies can strengthen their competitive advantage, mitigate risks, and contribute to positive social and environmental outcomes. As businesses navigate the complexities of global supply chains, CMRT 6.4 serves as a valuable tool for promoting accountability, sustainability, and integrity across industries. FAQs: CMRT 6.4 stands for Conflict Minerals Reporting Template version 6.4, released on April 26th, 2024. It’s a standardized reporting template developed by the Responsible Minerals Initiative (RMI) to help companies collect and disclose information about the presence and origin of conflict minerals in their supply chains. 2. What are conflict minerals? Conflict minerals, including gold, tin, tantalum, tungsten, and now cobalt, are minerals sourced from regions characterized by armed conflict and human rights abuses. These minerals are often used in various industries, including electronics, automotive, and aerospace.
ComplianceXL Secures a contract with a leading US manufacturer to support Conflict Minerals Compliance management
ComplianceXL has signed a contract with a US-based manufacturer of engineered products for industrial, commercial, and consumer markets worldwide. Under the multi-year blanket agreement, ComplianceXL will provide CMRT support services for their entire supply chain. An engineering leader serving a variety of end markets around the world, including industrial, commercial, and consumer markets, the client manufactures engineered products. Due to its global sales footprint, the client must ensure compliance with all major regulatory demands. Therefore, the client must maintain high standards of quality and safety. This system is regularly monitored and updated to ensure compliance with the latest regulations. The Conflict Minerals program by ComplianceXL will include supplier engagement strategy, CMRT collection, and validation, generating roll-up reports, a software platform to store all CoCs, and report submission. Therefore, the client will be able to manage complex products, markets, and supply chain networks while reducing CMRT reporting costs and time to market. Highlights of the engagement: According to CK Bharathan, Head of Compliance Solutions at ComplianceXL, this engagement will allow the client to manage compliance documentation effectively. As a result of this partnering, the client can streamline regulatory compliance management, ensuring seamless compliance with all applicable regulations.In addition, this engagement will provide them with the tools to monitor and enforce compliance requirements within the organization.
Update on CMRT: What’s New in Version 6.31?
The CMRT version 6.31 was released on May 26, 2023, and this addresses all the issues with the earlier CMRT v.6.3 which was reported to the RMI. On May 5, 2023, RMI released CMRT V6.3 as a major update to the conflict minerals reporting template. CMRT is a template developed by the Responsible Minerals Initiative (RMI) to identify the origin of minerals in products. With more updated information, RMI updates the CMRT template revision on a regular basis. The Conflict Minerals Reporting Template collects sourcing information on Tantalum, Tin, Gold, and Tungsten, also known as 3TG. Industry sectors like electronics, automotive, aerospace, jewelry, and others rely heavily on the CMRT. As a result of its role in encouraging responsible sourcing and supply chain transparency, it contributes significantly to the upholding of ethical standards, the protection of human rights, and the promotion of sustainable practices in these industries. For companies seeking to establish their Conflict Minerals status in the business market, the CMRT template has become a common and easy format to use. The latest revision to the CMRT CMRT version 6.3 has been updated with the following changes. Analyze and correct all bugs and errors that have been reported to RMI. Additional tips have been added to the Instruction tabs. There have been revisions made to the ISO short names for countries, states, and provinces. Updates have been made to the Smelter Reference list and the Standard Smelter list. In addition to the changes to the Declaration tab, Smelter list tab and Smelter Lookup tab on the 3TG Questionnaire, there were a few other changes. The following changes have been made. When Question 1 is answered as “NO” for the presence of 3TG, the answer cells for the remaining 7 questions turn “Grey” and the option in the dropdown becomes blank. This change will help to avoid contradictory answers from the suppliers for the 3TG questions. The dropdown option “100%” is missing in the answer cell for Question 6 – Tin which represents the percentage of the supplier response received when Tantalum is answered as “NO” for Question 1. This Correction is reflected in the new version. According to this year’s report, CMRT version 6.3 has undergone major modifications from its previous version. In a survey conducted by RMI, most supply chain members provided conflict minerals information using CMRT version 6.22. Since CMRT version 6.3 has been updated, RMI recommends using CMRT version 6.3 or higher for this year’s reporting. Which version of CMRT are you using for your Reasonable Country of Origin Inquiry (RCOI)? Learn how to adapt the new reporting template by speaking with one of our conflict minerals specialists. ComplianceXL helps collect 3TG information by sourcing the data from suppliers globally and validating it according to CMRT requirements. We strive to enable our customers to understand how high-risk smelters impact their supply chain. We are just a few weeks away from CMRT Reporting. It is important to remember to file your Company’s Form SD (Specialized Disclosure) and Conflict Minerals Report (CMR) with the Securities and Exchange Commission (SEC) by May 31, 2023.
All you need to know about the CMRT 6.22 update
On 11 May 2022, RMI released Conflict Mineral Reporting (CMRT) version 6.22. This is a free standardized reporting template developed by Responsible Minerals Initiative (RMI) for Conflict Minerals reporting. It helps in the process of transferring information related to three minerals (Tin, Tungsten, Tantalum, Gold) as well as their countries of origin. It also assists in identifying potential new smelters and refineries. Accordingly, identified smelters or refiners will undergo an audit by the Responsible Minerals Assurance Process (RMAP) of the RMI. On April 27, 2022, CMRT version 6.20 was released. The release included the fixing of all bugs and errors, updates to the smelter reference list and standard smelter list, as well as enhancements to translation. The latest version of CMRT, version 6.21, was released on May 6, 2022, with minor changes in the Smelter list tab. There were some minor revisions made to CMRT- 6.22 to address the reported issues, mainly related to the “Product list” tab. We anticipate releasing the next version of the CMRT in spring 2023.
All you need to know about Extended Mineral reporting template (EMRT) by RMI
In October of this year, the Responsible Mineral Initiative released a free, standardized report template, EMRT (Extended Mineral reporting template) v1.0. The purpose of this report is to gather compliance documents about Mica and Cobalt to be used in due diligence. In order to reduce costs and simplify supply chain surveying for downstream stakeholders, the EMRT was developed collaboratively by RMI members. The EMRT facilitates the exchange of information, such as the country of origin and the processors used to process minerals, along the supply chain. As a result, the company will be able to perform its due diligence for ensuring a responsible supply chain of minerals, refiners, and processors from high-risk and conflict-affected areas. EMRT focuses on the cobalt supply chain and natural mica supply chain at the moment. CMRT and EMRT are fundamentally different in that CMRT facilitates data exchange necessary for Dodd-Frank Act compliance through section 1502 of the Act. In the meantime, there are currently no regulatory requirements in place to ensure compliance for cobalt or mica. In addition to being provided to the customers, completed EMRTs can be posted on the company’s website as a good practice measure. Currently, RMI does not collect EMRTs. High-risk and conflict-affected areas are defined by the OECD as those with an armed conflict, widespread violence or other risks of harm to people. It can be an international or non-international conflict, involving two or more states, or it may be a liberating conflict. In high-risk areas, potential instabilities, institutional weaknesses, breakdowns in civil infrastructure, and widespread acts of violence are common. Cobalt refiner due diligence standard Version 1.0 was developed jointly by RCI (Responsible Cobalt Initiative) and RMI (Responsible Mineral Initiative). The standard is in effect until December 31, 2021. A new version of the Cobalt refiner due diligence standard, Version 2.0, will take effect on January 1, 2022. According to the schedule of release, the next version of EMRT is expected to arrive in 2022.
All you need to know about the new CMRT v6.1
RMI (Responsible Minerals Initiative) has released th new version of CMRT (Conflict Mineral Reporting Template) on 28th April 2021, which will replace the current version of CMRT v 6.01. The CMRT v 6.1 must be used for the next reporting year. For the current reporting year, all organization can use the CMRT v 6.01 or higher. The major changes that you will see in CMRT v 6.1 include: Corrections of all bugs and errors Smelter Reference List and Standard Smelter List updated (Incorporated few changes to the smelter list, based on updated Standard Smelter list as of 19 Feb,2021) Improvements in Translation. The next version of the CMRT is expected to be released during Spring 2022. The latest CMRT can be downloaded from here. Talk to our global compliance specialists today
How to ensure your CMRT is complete without errors?
The conflict minerals reporting template consists of 8 tabs out of which 3 tabs must be filled by the companies or Suppliers and 2 tabs to check the completion. Important points to be noted while filling the 3 tabs to avoid errors, Declaration Tab: On the Declaration Tab make sure all the fields marked as (*) / cells highlighted in yellow are filled. Provide appropriate answers for the questions asked in the Company information section. Try to reduce the number of characters you include in the Comments section and be concise. Enter the Company name and other company related answers in English for accuracy. Select Declaration Scope from the drop-down list only. Contact name and Authorizer can be same but enter the name completely in each respective cell instead of giving “Same as above, etc,.”. Email address of the Contact person and Authorizer should be in correct email format. The Effective date must be entered in International format DD-MMM-YYYY and it can only be past or present date. The 3TG Questions from 1 to 8 are all mandatory questions. Answers should be selected from the drop-down list only. When Question 1 and 2 is answered as NO, all other cells will turn grey indicating it is not required to fill. When Question 1 and 2 are answered as YES, all other questions will remain yellow until you fill the cells. Majority of the Clients/ Companies expect the response rate of their supply chain to be above 90%. Report all the Smelter information received by your Company in the CMRT. Every Company who uses 3TG in their products is recommended to have a Conflict minerals policy published in their website. The Policy information section allows suppliers to project the action taken for the Conflict minerals sourcing. Each Question in the CMRT is related to one another. While answering each question make sure it is logically connected with one another. For Example: When 3TG is sourced from covered countries and Question 3 is answered as YES, you cannot answer Question 5 as YES as the Question goes as “Does 100% of the 3TG originate from Recycle/Scrap?” Smelter List Tab: Smelter list is the section where majority of the errors occur. This section is required only when 3TG is used. Without Smelter list, the origin of the minerals cannot be found. Column A – Smelter Identification Number Input Column is not mandatory. You can leave blank or provide the same Smelter ID given in Column F. Column B – Metal, Column C – Smelter Look-up and Column E – Smelter Country are mandatory Columns and select them from the drop-down list only. Smelter name can be entered manually only when it is not listed in the drop-down. In this case try to provide more information about the Smelter location, mines, origin, contact details, etc., in the respective Columns. When Metal and Smelter Look-up is selected from the drop-down list, Column D (Smelter Name) will turn grey (not required to fill) and all other fields like Smelter Country, Smelter Identification number and Source of Smelter ID will be auto-populated. Do not copy/paste the Smelter information to the Smelter list tab. The text length should not be more than approx. 255 characters. Product List Tab: Product List should be filled only for Product level CMRT. Refer – How to prepare a Product level CMRT for more info. Points to remember to check the CMRT, Checker Tab: Checker tab helps to identify the complete and incomplete fields. The Completed fields are highlighted in green whereas the incomplete fields are highlighted in red. You have links which will direct you to the incomplete field. Note that this tab will only help to fill the CMRT but not to identify errors. Smelter Look-up Tab: The Standard Smelter list provided by RMI is listed under Smelter Look-up tab. The Smelters listed under this tab only can be selected from the drop-down for relevant metals in the Smelter list tab. Provide correct Smelter name for correct Smelter ID. Refer Active Smelter list provided by RMI – http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/smelters-refiners-lists/export-all-active/ Refer Conformant Smelter list provided by RMI – http://www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/smelters-refiners-lists/export-all-conformant/ Conclusion: Use the most recent Standard template/version CMRT to collect information from your suppliers. This will be more efficient to consolidate the received supply chain data with accuracy. Conduct training programs and recommend you suppliers to participate in RMAP program to remain compliant. Review the CMRT completely before submitting. Talk to one our CMRT specialist today, to understand how you can address the Training and CMRT documentation requirements.
How to prepare a Product level CMRT?
The major benefit of “Company level CMRT” is – It provides coverage for all the products manufactured by each manufacturer and helps both suppliers and manufacturers to utilize the same CMRT for different customers with a variety of products. In case, a customer requires only a Product level CMRT or if the manufacturer is not willing to provide a Company level CMRT then the below information would be more useful to complete your CMRT. Initially, the most important field in a CMRT is the Declaration Scope. This is the place that covers the total picture of a CMRT. To prepare a Product level CMRT, Select the Declaration scope as Product level from the dropdown under the Company Information section on the Declaration page. A CMRT is incomplete without the product list for a Product level CMRT. To include the Product list, you can either click the link given on the Description of scope(below Declaration scope) which appears only after you select the Declaration scope as Product level, or move to the Product list tab and enter the product details directly. On the Product list tab, the details of the products must be entered in the appropriate column. The Manufacturer Product number is the mandatory field that needs to be filled for a Product level CMRT. Other columns are optional. Remember the CMRT must include the 3TG information of all the products listed on the Product list tab. Once the Product details are listed on the Product list tab, the product list field on the Checker Tab will turn green indicating the field is complete else it will remain red. Finally, the time and effort of the supply chain management team would be less for preparing a Product level CMRT when compared to a Company level CMRT. So, the response rate of the suppliers would go high with well-analyzed Smelter analysis data. Some of the important steps to avoid errors on the Product level CMRT/ Common errors are: Select the Declaration scope only from the drop-down given. Do not enter manually. The product list is mandatory. Do not leave the Manufacturer Product number column blank and enter contents in the ‘comments’ column. Make sure the product list is entered from the 1st row of the Product list tab. At ComplianceXL, we simply compliance documentation and reporting for various material compliance needs with the help a dedicated supplier engagement team. Talk to one of our global compliance specialists today and get answers for all your questions related to the Conflict Minerals regulation.