Overview#
Conflict-minerals rules come down to one question: where did the tin, tantalum, tungsten and gold come from? Companies have to trace it so that revenues do not fund armed conflict.
The four minerals are 3TG: Tin, Tantalum, Tungsten and Gold. The CMRT is the industry-standard form used to collect their origin and smelter data up the supply chain.
The rules#
The EU Regulation's legal duty falls on upstream importers of 3TG ores and metals above the Annex I volume thresholds, not on companies that import finished products. Most CMRTs are still filled in downstream, driven by customer flow-down and US Dodd-Frank rather than a direct EU obligation. Note the geographic difference: Dodd-Frank §1502 targets the DRC and adjoining countries, while the EU Regulation applies to any CAHRA worldwide.
How the data is collected#
The Conflict Minerals Reporting Template (Responsible Minerals Initiative) collects smelters and country of origin for 3TG.
Like material declarations, this is a supply-chain data problem. You survey many suppliers, normalise their responses, and roll them up, the same pattern as a Full Material Declaration.
What a CMRT looks like#
A simplified, illustrative slice of the RMI Conflict Minerals Reporting Template. The real workbook (latest 6.6, April 2026) has full company info, all eight use-status and A–H policy questions, and a smelter list. Always fill in the current template from RMI.
Tap a row marked with ⓘ for an explanation. · responsiblemineralsinitiative.org ↗