Conflict Minerals Reporting refers to the documented due diligence for specific minerals that may originate from conflict-affected regions, where their extraction could finance human rights violations, armed conflict, or forced labor. The most recognized reporting framework is the Conflict Minerals Reporting Template (CMRT) from the Responsible Minerals Initiative (RMI)—a standardized form used in global supply chains to document the origin and processing path of these minerals.
For automotive suppliers and electronics manufacturers, the CMRT is an established tool for supplier qualification. Although the underlying US law does not impose a direct obligation on European SMEs, the pressure through OEM supplier contracts makes it de facto binding.
The CMRT focuses on four minerals collectively known as 3TG: Tantalum, Tin, Tungsten, and Gold. These four were classified as conflict minerals under the US Dodd-Frank Act Section 1502 because their extraction in the Democratic Republic of the Congo (DRC) and adjoining countries has historically financed armed groups.
For an automotive supplier producing stamped parts, cast components, or electronics, there is a high probability that 3TG minerals are present in raw materials, tools, or purchased parts—even if they are not immediately visible.
The US Dodd-Frank Act Section 1502 has required US-listed companies to report annually to the SEC since 2012. This directly affects OEMs like Ford, GM, and Tesla, who pass this reporting obligation down their global supply chains.
The EU Conflict Minerals Regulation (EU 2017/821), in effect since January 2021, targets EU importers of 3TG ores and metals (smelters and refineries). While manufacturing companies that buy semi-finished products are not directly covered by the EU regulation, they are bound by the requirements of their direct customers.
The CMRT is a standardized Excel form developed by the RMI (current version: CMRT 6.x). It is divided into two main sections:
This includes basic information, contact data, and the scope of the survey. It also features policy questions: Does the company have a Conflict Minerals Policy? Does it conduct due diligence? Is it an RMI member?
For each of the four minerals, the company must document whether it is contained in their products, the countries of origin, and the Smelters or Refiners identified in the supply chain.
Key Evidence: Smelter Identification The "Smelter" is the point in the supply chain where ore is converted into metal; after this point, the origin of the mineral is no longer traceable. Only smelters certified by the Responsible Minerals Assurance Process (RMAP) are considered proof of conflict-free origin.
The biggest operational challenge is identifying smelters across several tiers of the supply chain.
A supplier buys stamped parts from a steel provider. The steel contains tungsten from a carbide tool used in the forming process. The tool comes from a supplier who bought tungsten powder from a metal dealer, who in turn sourced it from a smelter. This depth requires every tier-supplier to survey their own sub-suppliers. The CMRT is the instrument used to collect and pass this information forward.
Conflict Minerals Reporting addresses the same core issues as the German Supply Chain Act (LkSG) and the EU CSDDD—due diligence in the supply chain—but with a specific focus on mineral origin and armed conflict. Companies that have already established structured supplier surveys for human rights risks have a strong foundation for efficient CMRT reporting.
Formally, no—the Dodd-Frank Act only applies to US-listed companies. In practice, however, most European OEMs and global corporations require CMRTs from all suppliers to satisfy their own compliance policies and reporting duties.
The CMRT is a specialized industry form focusing strictly on 3TG minerals and smelter verification. ESG questionnaires are broader, covering environmental, social, and governance topics. CMRT reporting is a specific subset of a comprehensive ESG supplier management program.
This must be disclosed in the CMRT. It is not an automatic ground for exclusion, but OEMs may demand a switch to a certified smelter or require the smelter to pursue RMAP certification. Having "no information" about smelters is the worst position to be in during a CMRT audit.
The filled-out CMRT is typically sent directly to the requesting customer via email or uploaded to supplier portals (e.g., Coupa, Jaggaer). Unlike the IMDS, there is no single centralized database for CMRT submissions.