While the world comes to a standstill amidst the pandemic, few organizations have managed to keep up with little business operations continuity planning.

As far as the mining industry is concerned, RMI(Responsible Minerals Initiative) is taking several measures to accommodate user feedback and improve upon the existing Conflict Minerals compliance declaration templates.

In its continued efforts to improve regulatory compliance and support responsible sourcing of minerals from conflict-affected and high-risk areas, the RMI has released newer versions of the CMRT and CRT templates. Read further to know more about the changes made in the Conflict Minerals declaration template and its benefits.

What’s new with CMRT?

The Conflict Minerals Reporting Template (CMRT) came into existence in the year 2010 and was generated by the Responsible Minerals Initiative (RMI), which later became an industry-standard reporting template. CMRT assists companies in executing their due diligence to disclose information about their supply chains.

CMRT is applicable in a number of industries including Hi-Tech Electronics, Automotive, Construction, Energy, Industrial, and Medical.,

CMRT 6.0

On May 13th, 2020, RMI released an updated and revamped CMRT 6.0, bringing about much-needed changes to the existing mineral deceleration structure.

A noted and significant change in the CMRT 6.0 is that it also incorporates EU Conflict minerals regulation which was not present in previous version 5.12

Conflict Minerals Declaration Template - A Deeper Look

Declaration Tab : -

1) Company Information : -

CMRT 6.0: -

Noted change: - Phone - Authorizer field is not mandatory.

In the earlier version 5.12, the Phone Authorizer field was mandatory to be filled by companies.

Benefit: - In certain cases where the employee, who is filling the CMRT, might not have necessarily operate a company-issued mobile device and rather be using a device from a private mobile manufacturer. Under such conditions, he/she is not required to furnish details of the Phone - Authorizer.

2)  Declaration Scope: -

Noted Change:-  There are totally 8 mandatory questions.

In the earlier version 5,12, there were 7 mandatory questions to be filled which have now been changed to 8 questions.

The Addition

The question which has been added is “Do any of the smelters in your supply chain source the 3TG smelter from conflict-affected and high-risk areas?

Benefit:- The additional question will help authorities in formulating strategies wrt to conflict-affected and high-risk areas. Once the quantity of minerals sourced from conflict-affected areas is known, a data-driven approach can be used to find measures that help in bringing peace to these high-risk areas.

3) Company Level : -

Updated questions in CMRT 6.0

QC from CMRT version 5.12 has been removed from version 6.0

QH is with regards to filing for SEC or with EU or both

Noted changes:

●  1 question is removed - Do you require your direct suppliers to be DRC conflict-free?{*}

●  1 question’s applicability is increased to both EU(European Union) or SEC(Securities and Exchange Commission) or both - Is your company required to file an annual conflict minerals disclosure?{*}

Benefit:

Owing to the earlier and ongoing BREXIT negotiations there were uncertainties regarding conflict minerals disclosure for the industries operating out of the European region. By increasing the applicability to both EU and SEC, the RMI has ensured everyone adheres to the declaration guidelines irrespective of the operating region.

Smelter List Tab:

Noted Change:- ISO short names for countries, states/provinces have been updated in version 6.0

One of the examples is: -

CMRT 5.12: -

MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF

CMRT 6.0: -

NORTH MACEDONIA

Benefit:- RMI has updated short names of countries in compliance with ISO(International Standards Organization). This new change ensures the conflict minerals declaration is carried out keeping in mind all the international standards and regulations.

Smelter Lookup Tab: -

Noted Change :- Smelter lookup tab has been updated based on recent RMI audit status.

To  download CMRT template the latest version, click here

Cobalt Reporting Template (CRT)

The Cobalt Reporting Template (CRT) was launched in the year 2018, by the Responsible Business Alliance (RBA), and became a standard reporting template for industries using the mineral Cobalt in their operations. The CRT was created to collect information about the smelters & refiners being used and mineral country of origin.

A large number of manufacturing businesses depend on cobalt. Some of them include Electric Vehicles(EVs). Li-ion battery manufacturers, polyester, tires, Aerospace, Defence, Power Generation, and High-speed steel.

On May 13, 2020, a newer and updated CRT version 2.1 was released.

The new changes are as follows: -

●  Corrections to Japanese translation of the definition of "Intentionally added"

●  Updates to the Smelter Reference List and Standard Smelter List

Benefit

More smelters have been added to the existing Standard smelter list and smelter reference list. This implies more smelters being officially recognized by RMI in its mission bring regulatory reforms in minerals mining.

To download the latest CRT 2.1, click here

Summing up

All major industries across the world will face new uncertainties post the COVID 19. Supply chain is predicted to be more process-oriented capable of handling newer challenges ahead. Under these situations, regulatory compliance become much more relevant.

APA Engineering, with 20+ years of experience, has helped thousands of businesses with managed solutions for regulatory compliance declaration.  We can assist you in every possible manner to ensure each and every compliance is followed and reported rigorously, saving you from future troubles. For more information as to how APA Engineering can help your business, get in touch with us.

   

If this regulation is applicable to you and you are interested in knowing more about this topic and available solutions, then schedule a free consult with our experts.