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.
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.
Importance of CIQs – Company Identification Questionnaires
Are you worried that your Smelter or refiner is currently not listed on the Standard Smelter Reference list? Relax!!! RMI has designed a questionnaire template to include the smelter or refiner details to solve the issue. The term CIQ stands for Company Identification Questionnaire. CIQ was previously known as Smelter Identification Questionnaire (SIQ). This is a key survey tool designed to collect information on a company’s mineral supply chain, minerals operation, production and helps to determine the eligibility of a company to participate in Responsible Minerals Assurance Process (RMAP), including any RMI’s due diligence, ESG standard and Downstream Assessment Program (DAP). Any individual Company information collected through the CIQ will not be shared publicly by RMI. Every manufacture/supplier who wish to participate in RMAP or DAP assessment must first fill the CIQ to start the process. The general CIQ supports the input for 3TG, Cobalt, Mica and DAP. The Company Identification Questionnaire can be downloaded using the below link Click to download To add smelters and refiners for any other minerals excluding 3TG, Cobalt and Mica, the Emerging Minerals Company Identification Questionnaire can be used. The Emerging Minerals Company Identification Questionnaire can be downloaded using the below link Click to download The completed questionnaires must be emailed to [email protected] for further processing. As a corrective action for suppliers with non conformant smelters in their supply chain can participate in this program with help of ComplianceXL, we shall survey on behalf the suppliers and help smelters refiners to be RMAP audit conformant.
EU targeting responsible sourcing of Minerals used in RE and EV technology
The project RE-SOURCING is funded by the European Union’s Horizon 2020 research and innovation program and developed for Renewable Energy, Electric Vehicles, Mobility, and Electronics who depend mainly on key minerals and hence targeted for responsible sourcing. The EU’s goal is to develop a platform for the global stakeholders for responsible sourcing and ensure the usage of carbon reduces in future. The minerals targeted for responsible sourcing are quartz in photovoltaic cells, tantalum in electronic devices, Copper in wind turbines, lithium in batteries and Gold in computer microchips. The basic aspect of the EU is to identify and reach out to the stakeholders and analyze the input of the stakeholders from where the mineral is being sourced and will be sourced in future. This input to the RE-SOURCING process will help to ensure that the minerals sourced do or do not cause negative impacts on the environment and society. The Local organizations and professionals play a vital role in guiding and supporting the EU’s regulations and policy to achieve the planned results. In the first annual conference of the RE-SOURCING Project held in January 2021, EU announced a list of drivers impacting the implementation of Responsible Sourcing (RS), defines approach and the role played by various stakeholders involved across mineral value chains, from extraction to end-of-life product management. As a result, the RE-SOURCING initiative is an important step for achieving decarbonization and transition to renewable energy. Are you into Renewable Energy, Automobiles, and Mobility? Talk to one of our Compliance Experts today and be future ready for compliance.
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.
EU Conflict Minerals Regulations will apply across the EU on 1st Jan 2021
It is on 17 May 2017 the EU Parliament and EU Council had laid down new import regulation on ‘Conflict Minerals’ under Regulation 2017/821. The importers of Tin, Tantalum, Tungsten and Gold (3TG) into European Union are required to carry out due diligence on their supply chain. Before importing, they are entitled to confirm whether the 3TG minerals and metals they import have been mined and processed as accepted norms in regulation. The regulation is introduced to make sure the 3TG minerals traded are not funding security forces or armed groups in areas of conflict. The EU conflict minerals regulation will ensure That EU importers of 3TG are responsible for sourcing standards set by the Organisation for Economic Co-operation and Development (OECD) That global and EU smelters and refiners of 3TG are sourced responsibly To help break the link between conflict and exploitation of minerals illegally; and To help and support local government to put an end to the exploitation and abuse of local communities, including mine workers. The raw materials such as tin, tantalum and tungsten, their ores, and gold are covered under the EU ‘Conflict Minerals’ Regulation, companies importing these minerals used in producing medical devices, mobile phones, technology, automotive products, as well as jewellery, will have to be compliant with standards defined as per the regulation. These regulations imposes a five step framework for importers, which the Organisation for Economic Co-operation and Development (OECD) has defined in a document called ‘Due Diligence Guidance for Responsible Supply Chains from Conflict-Affected and High-Risk Areas’ (OECD Guidance). The Importer needs to establish an internal management system; There should be no leniency in Identifying and assessing the risks in the supply chain; Implement a strategy to respond to identified risks; Under OECD Guidance, importers are required to carry out an independent third-party audit of supply chain due diligence; Importers have to report supply chain due diligence on an annual basis. The EU Member States can choose to enforce this regulations, ex-post checks of how union importers comply with the Conflict Minerals Regulations. This includes audits of records as well as on-the-spot inspections.
All you need to know about Conflict Minerals
We regularly use various products most possibly containing so-called conflict minerals—rare natural resources such as tantalum, tin, tungsten and gold (3TG), the mining and trade of which results in financial conflicts and human abuse in the Democratic Republic of Congo (DRC) and the adjoining countries. What is covered in this blog to help manufacturers and suppliers? The challenges in conflict minerals reporting program. Why conflict Minerals training is important for your business and your suppliers. How important it is to file under SEC/ to follow/ comply with CM regulation. What does the Dodd-Frank Wall Street Reform Act do? Dodd-Frank 1502 was the first Financial Reform Legislation signed by Former President Barack Obama in 2010 to distinguish between conflict and conflict-free mines. The main goal of the rule is to choke off funding for warlords and militants committing atrocities to run the mines using forced labor and abusive actions. As many companies think, the law does not require companies to stop sourcing 3TG from DRC and also does not force to source from conflict-free mines. The law only requires companies to file under SEC to report on the RCOI (mineral sourcing) and due diligence process. It creates transparency among companies which will help to sell or buy products with assured satisfaction to the suppliers and customers. This will enhance a company’s reputation as a good corporate member by avoiding the purchase of raw minerals from conflict mines and also supporting the law against human abuse. The law is still on its path to reduce the trade of armed militants by significantly reducing the price of conflict-free 3TGs than the price of conflict-3TGs. The high cost and lack of demand created a two-tier market with positive approach for conflict-free mines. This reduces the number of conflict mines in DRC regions. Approximately more than 75% companies and suppliers accepted the justice behind the law and started to follow the guidelines provided by SEC. Supplier’s interest on conducting RCOI, due diligence process and third-party audits is increasing day by day. These actions will improve the Business strategies, Compliance status, Supply chain management and financial performance of a company in the wide and wild corporate world. How to become conflict-free? A Company needs to form cross-functional teams to efficiently track the source of minerals through supply chain management. It is very important to decide whether to blindly comply with the requirements of the law or to perfectly agree and try to work towards the goal. As we think this is not an easy task to withstand ones Companys’ reputation and goodwill among the Competitors, no matter what, they have to stand against conflict mines and ensure that their tier suppliers also supply conflict-free minerals. It is really good to sign a Compliance agreement with the tier suppliers, distributors, smelters or refiners to prohibit the use of conflict minerals. Once the strategy is set, it is the management’s responsibility to accomplish the task efficiently. Do you have a question that whether your company is subject to SEC rule? According to the legislation, the law applies only to publicly traded companies of SEC jurisdiction in U.S. However, it is necessary to comply with the law even if your company does not fall under SEC rule, as your suppliers or distributors may comply with the law. Similarly, your tier suppliers down the globe may require companies including private sectors to remain conflict-free to lead a good business relationship. So, the law gives an international impact, affecting countless number of companies worldwide. Compliance Challenges: The first and foremost challenge would be the cost to track down the entire supply chain. The more complex a product, the more complex would be to trace the origin of the minerals used in the product. Aligning thousands of suppliers on a single chain is a huge and costly challenge. After all that, the process is time consuming and error-prone. Thus, compliance documentation becomes impractical for many companies. Apart from challenges faced by the companies on cost and supplier tracking, Compliance activities play a high priority role in most of the industries. Compliance Strategies: Affected companies are under pressure to take action and develop a strategy to comply with the law. Few steps to lead the compliance path- Determine whether your company complies with the SEC law. Understand the legislation established and how it affects your company. Form efficient team to handle the supply chain activities. Conduct a RCOI process to confirm the origin of the minerals used in the products. The RCOI can be processed through EICC and GeSI’s framework. If your products are sourced from DRC regions, then go for due diligence process and third-party audits. The framework developed by OECD is the only available guidance for due diligence process. Initiate trainings and seminars to make the suppliers understand the importance of the Act. Make sure your requirements are clearly explained. This include the Companies responsibility to build a good compliance chain. Review the data gathered from the entire supply chain and take necessary actions. Request your suppliers to remain conflict-free. Prepare a detailed Conflict minerals policy to share with your tier suppliers. File the Conflict Minerals Report (CMR) annually. Eliminate the contact with conflict suppliers for the next reporting as that will help to grow your business relationship with other suppliers and moreover remember that the competitors are gradually increasing in compliance field. These steps are similar to climbing a mountain. Fortunately, there are numerous data services companies to reduce your company’s burden and support them in Compliance. This will enable your company to face and overcome the challenge of managing, collecting and reporting conflict minerals information with less time and human effort. Finally, the most important target to meet, customer’s requirement and satisfaction, will be accomplished. Our compliance services focus on training, capacity-building and delivering strategy that allows companies to create efficiencies of their supply chain compliance. Talk to our compliance experts to learn more about being compliant to conflict mineral regulation and mitigate supply chain risks.
CMRT & CRT Update
New Version of Conflict Mineral Reporting Template CMRT v 6.01 and Cobalt Reporting Template CRT v 2.11 is released by RMI. CMRT v 6.01 (Conflict Mineral Reporting Template) RMI has released the new version of CMRT on 19th May 2020, which will replace the current version of CMRT v 5.12. The CMRT v 6.01 must be used for the next reporting year. For the current reporting year, all organization can use the CMRT v 5.1 or higher. The major changes that you will see in CMRT v 6.01 include: Corrections of all bugs and errors Updated ISO country, state and province lists Conformance to IPC-1755, which incorporated EU Conflict Minerals Regulation in the wordings of the following questions: Q 4 (newly added), Q H (formerly Q I), removal of former question C Updates to the Smelter Reference List and Standard Smelter List The next version of the CMRT is expected to be released during March-April 2021 CRT v 2.11 (Cobalt Reporting Template) RMI also updated the CRT (Cobalt Reporting Template) to CRT v 2.11 on 19th May 2020, which will replace the current CRT v 2.0 released on 30th October 2019. The Cobalt Reporting Template is a free, standardized reporting template developed by the Responsible Minerals Initiative to identify choke points and collect due diligence information in the cobalt supply chain. The template was formally launched on December 21, 2018. The major changes to the CRT v 2.11 are updates to the Smelter Reference List, which includes Cobalt Crude refiners that are designated Eligible in the Smelter Database. The next version of the CRT is expected to be released during September-October 2020 Talk to our global compliance expert to get help with your Conflict Minerals and Cobalt Compliance programs, that covers supplier training, CMRT / CRT collection and a robust supplier engagement platform or write us at [email protected]
Conflict minerals in EU – What it means for you and your business.
It’s a most conversable topic in the environment and material compliance space; In 2010, US Congress passed the Dodd-Frank Act, with rules requiring SEC listed companies to disclose their use of conflict minerals viz., Tantalum, Tin, Tungsten or Gold (3TG). The purpose of the rule was to keep a check on exploitation and trade of conflict minerals by armed groups is helping to finance conflict in the DRC region and is contributing to an emergency humanitarian crisis. Starting January 2021, a new law will apply across the EU – “the Conflict Minerals Regulation” As the world’s biggest trading bloc, the European Union has a responsibility to contribute to fair, transparent and value-based trade. This is a big step in that direction. It aims to help stem the trade in four minerals such as Tantalum, Tin, Tungsten and Gold, which are used in the production of everyday products like mobile phones, cars and jewellery; which sometimes finance armed conflict or are mined using forced labor. The structure of this guidance defines frameworks, policies, measures and supplements to determine due diligence processes for responsible supply chain of minerals from conflict-affected and high-risk areas, consistent with applicable laws and relevant international standards. A Five-Step Framework: EU importers will have to carry out checks on their supply chain by following a five-step framework, as defined in the ‘Organisation for Economic Co-operation and Development (OECD)’ guideline: Inside and outside the EU Indirectly, the regulation affects smelters and refiners of Tantalum, Tin, Tungsten and Gold, both inside and outside the EU. This is because EU importers of minerals and metals will need to make sure they source from responsible smelters and refiners i.e.; the regulation focuses on conflict minerals from all “conflict-affected and high-risk areas” around the world. In this way, the EU regulation is different from the US rule, which focuses on conflict minerals only from the Democratic Republic of the Congo and adjoining countries. For “upstream” companies who import raw materials to smelting and refinery plants in the EU. This covers the vast majority of such metals and minerals imported to Europe. The particular needs of small companies will be catered to so as to avoid subjecting them to overly cumbersome procedures, by exempting recycled minerals, and imports of very small volumes. For “downstream” companies, that use the refined forms of these metals and minerals in components and goods, the Commission will now carry out a number of measures. These include the development of reporting tools and standards to further boost due diligence in the supply chain, as well as setting up a transparency database. Those downstream operators who import refined, metal-stage products into the EU will be covered by the mandatory obligations. Through a review clause, there is also the possibility for the Commission to propose further mandatory obligations for the downstream supply chain if deemed necessary. Third party report In addition to the framework, companies are also required to provide third-party audit reports on smelter and refinery diligence practices. They must identify and assess the risks of adverse human rights impacts in their supply chains. Importers that pursue risk mitigation efforts as they continue to trade with, or even if they temporarily suspend trade with, certain suppliers are required to consult with suppliers, government authorities, civil society organizations, and other third parties on a risk mitigation strategy. How do you ensure compliance? One of the key challenges that companies face today is huge gap in supply chain traceability and related documentation, which is critical to make the compliance assessments and declarations. The Supplier base is today not able to deliver the required compliance data, such as Certificates of Compliance or Material Source information, which is critical for a legitimate compliance program. Enventure is today a leader in the compliance space, providing a host of solutions that enable customers to meet their regulatory compliance obligations. With services ranging from Consulting to Gap Analysis to Training and Data Collection, Enventure is able to provide comprehensive solutions, which are tailored to customer specific needs and priorities. Our unique ability to handle standard off-the-shelf parts, as well as custom parts sets us apart from the competition and makes the parts coverage best in class, since 2003, Enventure has assisted over 600 global corporations in fulfilling their regulatory & environmental compliance requirements within stipulated timelines, and with high levels of cost efficiency. Our customers include OE Manufacturers, Contract Manufacturers, as well as Distributors and Retailers.
Conflict Minerals Compliance – The Deadline Is Approaching
May 31, 2014 is a key date for all public companies listed with the SEC, as the first Conflict Minerals Report has to be filed by this day. The Conflict Minerals Rule enacted by the SEC,as part of the Dodd-Frank Wall Street Reform and Consumer Protection Act, requires certain public companies to provide disclosures on the use of conflict minerals in their products and whether they originated at mines run by warlords in the Democratic Republic of the Congo (DRC) or its nine adjoining neighbors. Compliance is mandatory for all SEC “issuers”, including foreign issuers, that manufacture or contract to manufacture products where “conflict minerals are necessary to the functionality or production” of the product. The rule was enacted as part of an effort to curtail human rights abuses in Africa by regulation of US public companies and also to provide transparency into corporate practices. The SEC rule does not specifically ban use of materials from such mines, but it requires companies to track and report the origin of the minerals through their supply chain. The aim is to dissuade companies from using minerals sourced at mines where human rights abuses take place and not engaging in trade that facilitates regional conflict. The SEC disclosure process involves the following steps Minerals that are not conflict free must be listed in the Conflict Minerals Report, which must be audited by an independent auditor. Additional documentation is also required for any materials that come from the affected countries to show that it meets the Organisation for Economic Co-operation and Development (OECD) due-diligence procedures documenting and the materials are conflict free. The first Forms under the rule will be required for the calendar year ending December 31, 2013 and will need to be filed by 31 May 2014. For most companies compliance with the Conflict Minerals Rule will not be easy and will be time consuming with the SEC estimating that initial compliance costs could be between $3 billion to $4 billion,as the complete supply chain needs to be analyzed for source of minerals, particularly those contained in procured parts, assemblies or items purchased from vendors. The fact that the supply base is not geared to address these requirements and the information provided by them is not always accurate only adds to the challenge. Hence, it requires multidisciplinary teams working across product lines and tracing multiple supply chains for these materials and their origin. On one hand, committing to using only conflict-free materials can mean paying higher costs for those materials but on the other hand a company’s reputation and goodwill is at risk if its products include conflict minerals. Despite the challenges and oppositions raised against various sections of the rule in court, experts believe that ultimately compliance will be mandatory and in fact will be extended to include more industries currently exempt from the rule. Therefore, a company that is committed to a conflict-free business plan can leverage its status towards strategic competitive advantage and be seen as a good corporate citizen. Enventure is an industry leader in the compliance space and is one of the first companies to offer engineering services that will help you comply with this regulation.