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Kimball Electronics
Tolomatic
Industrial Scientific
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FLUKE
Kimball Electronics
Tolomatic
Industrial Scientific
AHEAD
roboception
By Deepa Shetty | Thu Mar 23 2023 | 2 min read

Table of Contents

The Conflict Minerals Reporting Template (CMRT) is a standardized tool designed to help companies collect and disclose data on the use of conflict minerals—tin, tungsten, tantalum, and gold (3TG) in their supply chains. Managed by the Responsible Minerals Initiative (RMI), the CMRT aligns with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (CAHRAs).

What is the Purpose of the CMRT?

The CMRT is a global tool used across industries to promote supply chain transparency and compliance with conflict minerals regulations. Its primary purposes include:

  • Data Collection: Facilitating the collection of supplier data on 3TG minerals within the supply chain.
  • Compliance Reporting: Helping companies meet the requirements of the U.S. Dodd-Frank Act Section 1502 and the EU Conflict Minerals Regulation.
  • Public Disclosure: Enabling businesses to disclose sourcing information to investors, customers, and other stakeholders.
  • Smelter Identification: Supporting the RMI’s Responsible Minerals Assurance Process (RMAP) by identifying new smelters and refiners for potential audits.

The latest CMRT version (6.4), released in April 2024, includes bug fixes, updates to smelter lists, and enhanced formatting for improved usability.

Who Needs to Report on Conflict Minerals?

Companies required to report on conflict minerals include:

Download our Conflict Minerals eBook to learn more about Responsible sourcing in detail.

Both regulations require companies to conduct due diligence on their supply chains and disclose the origin of their conflict minerals annually. The RMI recommends updating the CMRT at least once a year to maintain accurate and transparent supply chain data.

What Information is Required to Complete a CMRT?

The CMRT template consists of eight sheets, some of which provide instructions, while others require supplier input. The data collected falls into four main categories:

  1. Company Information:
    • Supplier details, including company name, contact information, and reporting year.
  2. Due Diligence Information:
    • Questions related to the use of 3TG minerals, regulatory applicability, and the supplier’s responsible sourcing efforts.
  3. Product List:
    • A reference to part numbers and product-level declarations.
  4. Smelter List:
    • Identification of smelters and refiners used in the supply chain, including their location and certification status.

Step-by-Step Guide to Completing the CMRT

  1. Download the Template: Access the latest CMRT version from the RMI website to ensure compliance with current standards.
  2. Gather Company Information: Compile your company’s details, including contact information and reporting year.
  3. Identify Suppliers: List all suppliers involved in the use of 3TG minerals and gather their contact information.
  4. Define Product Scope: Specify the products subject to reporting, including categories and models.
  5. Request Smelter Information: Collect details about smelters and refiners, including their name, location, and materials processed.
  6. Document Due Diligence: Ask suppliers to share information about their responsible sourcing measures, including policies, surveys, and audits.
  7. Trace Mineral Origin: Determine the countries of origin for all 3TG minerals used in your products.
  8. Validate Data: Ensure all collected information is accurate, complete, and consistent with your records.
  9. Compile Reports: Consolidate supplier data into a single CMRT submission, ready for internal or external reporting.

Here is how CMRT data flows within different stakeholders in the supply chain:

CMRT process flow.jpg

What is the Difference Between CMRT and EMRT

While the CMRT is used for reporting on 3TG minerals, the Extended Minerals Reporting Template (EMRT) focuses on other materials like cobalt and mica. Key differences include:

  • Mandatory vs. Voluntary: The CMRT is mandatory for companies under conflict minerals regulations, while the EMRT is voluntary, typically used to meet sustainability goals.
  • Minerals Covered: CMRT addresses 3TG, whereas EMRT covers extended minerals outside the conflict minerals category.

How Acquis Can Help with CMRT Reporting

The Acquis Compliance Tool simplifies conflict minerals reporting with a suite of features tailored to meet regulatory requirements:

  • Automated Data Collection: Streamline the CMRT process with automated supplier outreach and smelter risk analysis.
  • Multilingual Support: Overcome language barriers to improve supplier engagement and response rates.
  • Data Visualization: Generate exportable reports and dashboards for internal and external stakeholders.
  • Regulatory Expertise: Access guidance from in-house compliance experts to ensure accuracy and compliance with evolving regulations.
  • Scalability: Adapt to additional reporting needs, such as EMRT and STRT, as your business grows.

With Acquis, you can gain supply chain visibility, reduce risks, and meet compliance standards efficiently. Take the first step toward responsible sourcing today. Contact us to learn how Acquis can transform your compliance journey.

Topics

Conflict MineralsResponsible SourcingUSA RegulationsSustainability Software

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What is the Conflict Minerals Reporting Template

The Conflict Minerals Reporting Template (CMRT) is a standardized supply-chain disclosure tool developed by the Responsible Minerals Initiative to help companies identify and report the use of tin, tungsten, tantalum, and gold (3TG). It is required because global conflict minerals laws demand transparency into mineral sourcing from conflict-affected and high-risk areas (CAHRAs). The CMRT operationalizes due diligence expectations under the Organisation for Economic Co-operation and Development Due Diligence Guidance.
CMRT reporting applies primarily to U.S. publicly listed companies subject to Dodd-Frank Act Section 1502 and EU importers regulated under EU Conflict Minerals Regulation. However, CMRT requests cascade through global supply chains, meaning suppliers at all tiers are frequently required to complete CMRTs contractually—even if they are not legally obligated themselves.
A CMRT requires suppliers to disclose company information, due diligence practices, product scope, and detailed smelter and refiner data for 3TG minerals. This includes identifying smelters by name and country, confirming audit status under the Responsible Minerals Assurance Process, and declaring whether minerals originate from CAHRAs. Incomplete smelter data is one of the most common CMRT failure points
The CMRT acts as the primary data-collection mechanism that enables companies to meet annual reporting, reasonable country-of-origin inquiry (RCOI), and due diligence disclosure obligations. It allows companies to aggregate supplier data into defensible compliance records that support SEC filings, EU regulatory disclosures, customer audits, and investor ESG reviews.
The most frequent issues include submitting company-level CMRTs instead of product-level declarations, listing smelters without validation, using outdated CMRT versions, and failing to refresh data annually. Regulators and downstream customers increasingly expect current CMRT versions, traceable smelter logic, and documented follow-up when suppliers report high-risk or unknown smelters.
The CMRT is focused exclusively on conflict minerals (3TG) and supports mandatory legal compliance. The EMRT (Extended Minerals Reporting Template) expands disclosure to materials such as cobalt and mica and is typically driven by customer ESG requirements rather than statutory mandates. Many manufacturers now run CMRT and EMRT workflows in parallel to meet both regulatory and sustainability expectations.
Best practice—and Responsible Minerals Initiative guidance—recommends updating CMRTs at least annually or whenever there are material supply-chain changes. In 2026, static CMRTs are considered high-risk. Companies are expected to demonstrate continuous due diligence, supplier engagement, and escalation when smelter or sourcing data changes.