After China’s Ministry of Commerce placed the Responsible Business Alliance on its countermeasures list, the Responsible Minerals Initiative has extended the validity of the most recent completed RMAP assessment for smelters and refiners in China until further notice. Those facilities keep their status on the RMI public list — but their audits are frozen rather than current.
What Happened
China’s Ministry of Commerce, by Order No. 2 of 2026 effective 5 August 2026, placed the Responsible Business Alliance — parent of the Responsible Minerals Initiative — on its countermeasures list, prohibiting organisations and individuals within Chinese territory from engaging in transactions and cooperation with the listed entities. On 17 August 2026 the RBA published a statement responding to the decision. It states that the measures apply to entities and individuals operating within China, and that RBA operations outside China are not affected. As an interim measure, the RMI will extend the validity of the most recent complete RMAP assessment for smelters and refiners located in China until further notice, allowing those facilities to maintain their current status on the RMI public list while the organisation evaluates its next steps.
What’s New
- RMI has suspended normal RMAP re-audit expiry for China-domiciled smelters and refiners rather than delisting them — the interim measure runs until further notice.
- Affected facilities retain their current status on the RMI public list, so a conformant designation may now rest on an assessment that would otherwise have lapsed.
- The RBA states that the Chinese measures apply to entities and individuals operating within China and that its operations elsewhere are unaffected.
- Because a large share of tantalum, tin, tungsten, gold, cobalt, lithium, graphite and mica processing capacity sits in China, this reaches the conformant-smelter data underpinning CMRT and EMRT declarations, EU Conflict Minerals Regulation due diligence and EU Batteries Regulation due diligence.
- This is the first time a major responsible-sourcing scheme owner has been designated under China’s counter-sanctions framework.
Key Dates & Timeline
MOFCOM Order No. 2 of 2026 takes effect, listing the RBA
RBA statement published; RMI extends RMAP assessment validity for China-based facilities
Duration of the RMAP validity extension
Affected Industries
All · Light duty vehicles · Heavy duty vehicles · Batteries · Electrical and electronic equipment · Powertrain · Smelting and refining
Who Is Affected
OEMs and Tier-n suppliers running conflict-minerals and battery due-diligence programmes; RMI member companies; smelters and refiners in China; procurement, sustainability and legal functions preparing CMRT and EMRT campaigns.
Standards / Products in Scope
RMAP assessments and RMI public-list status for smelters and refiners located in China, and the due-diligence declarations that rely on them.
Prohibitions, Restrictions & Requirements
The RMI measure is not a restriction but a relaxation of audit expiry. The underlying prohibition is China’s: parties within Chinese territory may not transact or cooperate with the RBA.
What Companies Should Do
- Re-baseline your smelter list against the RMI public list and flag China-domiciled facilities whose audits are now frozen rather than current — that distinction is what a diligent reviewer will ask about.
- Brief legal counsel before instructing Chinese suppliers to participate in RBA or RMAP activities, since the prohibition binds them, not you.
- Document the alternative assurance you rely on for those facilities, so your next conflict-minerals filing and your EU Batteries Regulation due-diligence file show a reasoned position rather than a gap.
- Raise the question with your industry association: a single voluntary scheme carrying this much of the industry’s due diligence is now a concentration risk, and the sector-level answer matters more than any one company’s workaround.
Nothing in your own filings changes mechanically, which is exactly why this is easy to miss. What changes is the evidential quality behind a conformant designation for a large share of the world’s processing capacity — and that is the thing you will be asked to defend, not the list itself.
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