Compliance Alert! RMI will Phase Out the CRT and MRT

In a recent announcement, the Responsible Minerals Initiative (RMI) announced their intention to phase out the Cobalt Reporting Template (CRT) and Mica Reporting Template (MRT) by the end of March 2022. As an alternative to using the respective templates for the various minerals included within the software, the RMI released the Extended Minerals Reporting Template (EMRT) in October 2021. As a result of the discontinuation of the CRT and MRT, manufacturers will be forced to switch over to the EMRT instead. The CRT and MRT webpages will be taken offline after March 31, 2022, and the templates will no longer be available to the public. What is EMRT? On 20 October 2021, the Responsible Minerals Initiative (RMI) and the IPC 1755 standards committee published the Extended Mineral Reporting Template (EMRT). The Cobalt Report Template (CRT) and Mica Reporting Template (MRT) are being merged into the Extended Minerals Reporting Template (EMRT) in order that exploration companies can gather information on Cobalt and Mica as part of the due diligence process. Furthermore, the EMRT represents a transition from mineral-specific individual templates in order to demonstrate a more holistic approach toward managing minerals responsibly. A key objective of EMRT is the fact that, as corporate social responsibility (CSR) matures, further minerals will need additional scrutiny, and industry needs a template designed to evolve and should be adoptable by nature. With ComplianceXL, manufacturers can use our managed solution for minerals reporting with access to a dedicated supplier engagement team. We offer manufacturers a solution with updated RMI guidelines for EMRT, including data collection and reporting for cobalt and mica due diligence. Contact our responsible minerals compliance experts to learn more about streamlining your cobalt, mica, or conflict minerals data collection program.

Did you know, EMRT is updated by RMI?

On December 23, 2021, a new version of EMRT 1.02 is released by RMI. This new release has only minor changes. The new release has corrected the issues reported in Chinese translation. Originally, Extended Mineral Reporting Template (EMRT) was published by the Responsible Minerals Initiative (RMI) and IPC 1755 standards committee on 20th Oct 2021. The Cobalt Report Template (CRT) and Mica Reporting Template (MRT) have been consolidated into Extended Minerals Reporting Template (EMRT) to enable exploration companies to gather information on Cobalt and Mica as part of the due diligence process. A supply chain data collection and sharing tool, the EMRT is designed for downstream companies to use as a method to gather and disclose supply chain data. In the past, there were separate reporting templates for Cobalt and MICA. The purpose of the EMRT is to increase the efficiency and ease the supply chain surveying process by increasing the use of technology. Unlike conflict minerals (CMRT), there is no regulatory compliance requirement for cobalt and mica as of now which are the current scope of EMRT. It is expected that the next release of EMRT will be released in the fall of 2022. EMRTs are not collected by the RMI. EMRTs should be provided to your customers as a good practice measure, and may also be posted on your external website. The latest EMRT can be downloaded from the Responsible Mineral Initiative Website. http://www.responsiblemineralsinitiative.org/media/docs/RMI_EMRT_1.02.xlsx The EMRT was designed in accordance with the Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas of the OECD. It was created to serve as an aid to corporate due diligence and to facilitate the identification of smelters and refiners. Schedule a free consultation with our experts if this regulation applies to you and you want to learn more about this topic and available solutions.

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.

Everything about Revised Cobalt Refiner Supply Chain Due Diligence Standard

RMI (Responsible Mineral Initiative) and RCI (Responsible Cobalt Initiative) published their revised Cobalt Refiner Supply Chain Due Diligence Standard on Aug 19,2021. The Responsible Cobalt Initiative (RCI) is initiated by the upstream and downstream companies in the global cobalt supply chain. It is dedicated in identifying, preventing and addressing the social and environmental challenges of cobalt supply chain with a systematic method, minimizing negative impacts, improving community livelihood, and building an inclusive, sustainable and responsible cobalt supply chain. This revised standard replaces the originally released 2018 due diligence standard of Cobalt refiner supply chain. This revised standard enables companies to also comply with the London Metal Exchange (LME); along with supporting companies’ due diligence and responsible production and sourcing activities within the cobalt value chain. A multi-year process to review the process and results of independent third-party assessments and receive feedback from refiners, auditors and customers, resulted in this revised standard. Major changes in Cobalt Refiner Supply Chain Due Diligence Standard Required data points captured by system of controls and transparency for all cobalt-bearing material received is clarified. Requirements to assess plausibility of material coming from declared sources is clarified. Articulation of further company risk management requirements. Addition of Step 6: Community Participation. It encourages companies to consider ways to effectively engage local communities to establish partnerships with artisanal miners, governmental and non-governmental organizations, and other stakeholders. The revised Standard included the principles and requirements of the Chinese Due Diligence Guidelines for Responsible Mineral Supply Chains and the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas. This standard encourages companies to source responsibly from Conflict-Affected ,High-Risk Areas ,artisanal and small-scale mineral producers. Procurement responsibilities not only include due diligence and risk management but also ,engagement with stakeholders in the supply chain .This will drive a positive impact for the local communities that are beyond the actions required under this Standard. Assessment of this standard will be done by an independent third-party OECD Alignment. Its also necessary to obtain formal approval by the LME. The revised Cobalt Refiner Supply Chain Due Diligence Standard can be downloaded from here. Talk to one of our Global Compliance Specialists today!

CRT 2.0 A New Update: Everything About RMI’s New Version of the Cobalt Reporting Template

RMI(Responsible Mineral Initiatives) has released revised version of Cobalt Reporting Template CRT 2.2 on 28th October 2020. The first version of the CRT was launched on December 21, 2018. CRT is developed by RMI to identify choke points and collect due diligence information in the cobalt supply chain. It is a standardized template and can be downloaded from the RMI website. The last version of the CRT 2.1 was released on May 2020 Below are the major changes incorporated in CRT v. 2.2 Updates to the Smelter Reference List Corrections to reported bugs on “Smelter List” tab Updates to the Smelter Look-up List and Standard Smelter List Updated ISO codes The next version of the CRT is expected to be released during September- October 2021

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]

RMI has released Cobalt Reporting Template Version 2.0 (CRT 2.0)

The Cobalt Reporting Template is developed by the Responsible Minerals Initiative (RMI) to identify choke points and collect due diligence information in the cobalt supply chain. This is a free standardised template and was launched on December 21, 2018. RMI has revised the CRT with effect from 30th October 2019 and the new version is CRT 2.0. The major changes compared to the earlier version are mentioned below: All bugs and errors were corrected Modified to conform as per IPC-1755 amendment dated May 2019 More clarity is given on the instructions and definitions Smelter Look-up tab and Instructions are aligned to CMRT in language and format The Smelter Look-up List and the Standard Smelter List are updated The next version of the CRT is expected to be released during September-November of next year, 2020. ComplianceXL has the new version of the Cobalt reporting Template and has been using it since, keeping in mind the best interest of their clients. Once the newer version is released, they will make sure to update you with the news. CRT 2.0 is available for download here. List of currently identified cobalt refineries can be found in the below link: CRT EXPORT

New Cobalt Reporting Template (CRT), How Is It Different From CMRT?

Cobalt was supposed to be the fifth conflict mineral along with 3TG (Tin, Tungsten, Tantalum and Gold) when Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act was introduced in the United States. It was dropped because of resistance from corporates. Their reason was that identifying and validating smelters became complex as cobalt is primarily processed as a byproduct of copper and nickel mining. Cobalt is the key element used in batteries of mobile phones, laptops, and electric vehicles and hence the demand for cobalt has been increasing year after year. The increased demand forced many suppliers to source the cobalt from DRC since they are the world’s leading producer of cobalt. As a result, companies using cobalt in their products are forced to do due diligence to ensure responsible sourcing. Since there are reports of unsafe mining practices and the use of child labor, RMI has launched a pilot Cobalt Template (CRT) on 1st March 2018 to understand the difficulties and bottlenecks for the collection of due diligence information in the cobalt supply chain. The pilot phase will run from 1 March 2018 to 31 August 2018. The Cobalt Reporting Template (CRT) is a standard reporting template created by the Responsible Business Alliance (RBA) to gather information regarding mineral country of origin, and smelters and refiners being utilized. The CRT is limited only to cobalt supply chains. The CMRT follows the IPC-1755 Standard, which does not currently include cobalt or questions related to the cobalt supply chain. The CMRT is intended, in part, to facilitate the exchange of data necessary for compliance with Section 1502 of the Dodd-Frank Act. Even though there are no regulatory compliance requirements in place for cobalt now, CRTs should be provided to your customers, as a good practice measure, and may be posted on your website. Please Read more about cobalt reporting to learn more about cobalt reporting and download the RMI’s cobalt reporting template (CRT). Are you an importer of Cobalt? and Do you want to know how to perform due diligence under Responsible Cobalt Initiative (RCI) and RMI? Talk to our experts at ComplianceXL.

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