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Industrial Scientific
AHEAD
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By Swetha Sankar | Wed May 14 2025 | 2 min read

EMRT Proactively Addressing Regulatory Risk Across Your Mineral Supply Chain

Cobalt, mica, copper, graphite (natural), lithium, and nickel—collectively known as extended minerals—are foundational to today’s electronics, EVs, and industrial applications. But their sourcing often comes with serious ethical concerns. These extended minerals are frequently mined in conflict-affected and high-risk areas (CAHRAs), raising red flags around human rights abuses, child labor, and forced labor.

Despite rising demand, there are no binding regulations requiring responsible sourcing of extended minerals—yet. However, ESG-focused companies and global supply chains are moving fast, using tools like the Extended Minerals Reporting Template (EMRT) to preempt regulatory risk and meet stakeholder expectations.

What Are Extended Minerals?

Extended minerals refer to a group of six high-impact materials:

  • Cobalt
  • Used in lithium-ion batteries, magnetic materials, alloys
  • Classified as a Critical Raw Material in the EU and U.S.
  • Major sourcing issues in the DRC, where over 50% of the world’s cobalt is mined under hazardous and exploitative conditions
  • Mica
  • Found in paints, cosmetics, electronics
  • Known for heat resistance and flexibility
  • Heavily linked to child labor in India and Madagascar
  • Copper
  • Used in wiring, motors, heat exchangers, plumbing
  • Excellent conductivity and corrosion resistance
  • Often mined in politically unstable or environmentally sensitive regions
  • Graphite (Natural)
  • Used in refractories and steelmaking
  • Known for high heat tolerance and conductivity
  • Included in EU Critical Raw Materials list
  • Lithium
  • Key material for batteries, ceramics, lubricants
  • High demand from EV and energy storage sectors
  • Geopolitical tensions tied to lithium-rich areas (e.g., South America, China)
  • Nickel
  • Integral to stainless steel, alloys, and EV batteries
  • Found in coins, cookware, personal care items
  • Mined heavily in Southeast Asia and Russia

These minerals are essential to modern life—but they bring real extended minerals sourcing challenges, from lack of traceability to unreliable supplier declarations.

Why Is Extended Mineral Mining a Problem?

Minerals Sourced from CAHRAs

Conflict-affected and high-risk areas (CAHRAs) are often controlled by armed groups and lack adequate labor protections. Mining in these zones perpetuates:

  • Child labor (particularly in mica mines in India, Madagascar)
  • Forced labor (notably in DRC’s cobalt mines)
  • Unsafe working conditions
  • Environmental degradation

Example: Cobalt in the DRC

Over 70% of cobalt comes from the Democratic Republic of Congo. In the absence of safeguards:

  • Workers (often children) are forced into toxic, hand-dug pits
  • Lung damage, injuries, and fatalities are common
  • Water and air pollution affect local communities

Limited Regulation, High ESG Risk

Currently, there’s no regulatory framework requiring companies to trace or report extended minerals. But stakeholder pressure—from investors, NGOs, and consumers—is pushing organizations to act now.

Why Report on Extended Minerals?

Reporting on extended minerals builds supply chain transparency and gets ahead of future regulations. By using tools like the Extended Minerals Reporting Template (EMRT), companies can:

  • Identify refiners and processors
  • Determine country of origin
  • Understand CAHRAs exposure
  • Conduct ethical mineral sourcing assessments
  • Align with OECD Due Diligence Guidance

Think of it as extended due diligence for extended minerals.

How the EMRT Helps With Data Collection

The EMRT provides a standardized way to collect, validate, and report extended minerals data. It includes:

  • Yes/No questionnaires for suppliers
  • Refiner/processor identification
  • Smelter alias cross-checking
  • Mine-level facility disclosures (v2.0+)

New in EMRT 2.0 (April 2025):

  • Copper, natural graphite, lithium, and nickel added
  • Optional Mine List tab
  • Updated Smelter Reference Lists

Use the EMRT to streamline your extended minerals due diligence—and demonstrate a real commitment to responsible sourcing of cobalt, mica, copper, and other critical minerals.

The Role of Acquis in EMRT Reporting

Acquis’s EMRT Minerals Reporting and Due Diligence solution helps you:

  • Manage supplier outreach for extended minerals
  • Validate and cross-reference EMRT data
  • Automate risk assessments for CAHRAs exposure
  • Generate due diligence reports aligned with ESG frameworks

This end-to-end support enables ethical sourcing decisions—before the legislation catches up.

Final Thoughts: Why Now Is the Time

As extended minerals become critical to the clean energy transition, global scrutiny on sourcing will only intensify. Companies that act now will:

  • De-risk their supply chains
  • Build ESG credibility
  • Prepare for future regulations

Read our guide on using the EMRT for extended minerals risk management or book a demo with Acquis to streamline your data collection.

Stay ahead. Source ethically. Own your supply chain story.

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Reporting on Extended Minerals - EMRT in Your Supply Chain

The Extended Minerals Reporting Template (EMRT) is an industry-standard tool developed by the Responsible Minerals Initiative (RMI) to collect supplier declarations regarding sourcing of minerals like cobalt, mica, copper, lithium, nickel, and natural graphite. It helps downstream companies support responsible sourcing in line with OECD guidance and emerging regulations.
Released in April 2025, EMRT 2.0 expands the template to include four new minerals copper, natural graphite, lithium, and nickel adds a Mine List tab, and updates the Smelter Reference List and UI enhancements.
CMRT focuses on conflict minerals (3TG: tin, tantalum, tungsten, gold). EMRT addresses extended minerals beyond 3TG—critical for batteries and electronics. AMRT provides fully customizable reporting for up to ten additional minerals not covered in CMRT or EMRT.
Manufacturers, brands, and suppliers involved in supply chains containing cobalt, mica, or other battery and tech-related minerals should deploy EMRT to collect data from their upstream partners supporting voluntary ESG compliance and emerging frameworks such as the EU Battery Regulation.
Supplier responses include: Mineral-specific smelter/refiner identification Country of origin and conflict-affected sourcing status Company policies and due diligence measures The template also optionally includes mine-level traceability in the new Mine List tab.
Challenges include low supplier adoption, confusion over version updates, inconsistent or incomplete data, and lack of clarity on whether cobalt or mica require EMRT vs CMRT. Overcoming these requires supplier training, version governance, and automated validation.
To use EMRT effectively: Request EMRT responses from suppliers when cobalt, mica, or other covered minerals are used. Use EMRT 2.0 (or newer) to align with regulatory needs and ensure the Mine List feature is leveraged. Maintain audit-ready traceability and reconciliation with supplier-provided data. Combine EMRT workflows with CMRT and AMRT where appropriate to future-proof against emerging mineral risk requirements.