What is the CMRT?
Understanding the Conflict Minerals Reporting Template
The Conflict Minerals Reporting Template (CMRT) is a standardized supply chain reporting template developed by the Responsible Minerals Initiative (RMI). It enables companies to collect and share due diligence information about tin, tungsten, tantalum, and gold—commonly known as 3TG minerals—in their supply chains.
The CMRT was created to support compliance with global conflict minerals regulations, including Section 1502 of the U.S. Dodd-Frank Act and the EU Conflict Minerals Regulation (EU 2017/821). It helps companies demonstrate responsible sourcing, supply chain transparency, and OECD-aligned due diligence for minerals that may originate from Conflict-Affected and High-Risk Areas (CAHRAs).
The CMRT captures essential data:
- Smelters and refiners processing 3TG minerals
- Country or region of origin
- Whether sourcing involves Conflict-Affected or High-Risk Areas (CAHRAs)
- Supplier sourcing and due diligence policies and practices
Instead of responding to multiple custom surveys, suppliers complete one standardized template and provide it to their customers. This improves consistency, transparency, and efficiency across the supply chain while supporting regulatory compliance and responsible sourcing objectives.
You can download the latest version of the CMRT directly from the RMI website.
What Minerals Are Included in the CMRT?
The CMRT covers four minerals commonly referred to as 3TG:
EU Conflict Minerals Regulation
EU Conflict Minerals Regulation
EU Conflict Minerals Regulation
EU Conflict Minerals Regulation
These minerals have historically been linked to armed conflict, forced labor, and human rights abuses, particularly in parts of Central Africa.
CMRT vs. EMRT – What’s the Difference?
The CMRT and EMRT are complementary reporting templates used for responsible minerals due diligence.
The Conflict Minerals Reporting Template (CMRT) focuses on 3TG (tin, tungsten, tantalum, and gold) minerals under:
- Dodd-Frank Act (Section 1502, United States)
- EU Conflict Minerals Regulation
The Extended Minerals Reporting Template (EMRT), by contrast, addresses additional minerals that are not traditionally covered by conflict minerals law but are increasingly regulated or required under ESG and battery legislation.
Today, many manufacturers must manage both templates simultaneously, creating new complexity in supplier communication and data consolidation.
- Covers 3TG (tin, tungsten, tantalum, gold)
- Focused on conflict financing
- Driven by Dodd-Frank & EU 2017/821
- Long-standing regulatory requirement
- Covers cobalt, mica, lithium, nickel, natural graphite, copper
- Focused on human rights + environmental risks
- Driven by ESG expectations & EU Battery Regulation
- Emerging due diligence and battery compliance driver
3TG Conflict Minerals: Dodd-Frank vs EU Regulation 2017/821
Two major regulatory frameworks drive the use of the CMRT: Section 1502 of the U.S. Dodd-Frank Wall Street Reform and Consumer Protection Act and the EU Conflict Minerals Regulation (EU) 2017/821. Both require companies to conduct supply chain due diligence on tin, tungsten, tantalum, and gold (3TG) and to disclose their sourcing practices.
U.S. Dodd-Frank Act (Section 1502)
Section 1502 of the U.S. Dodd-Frank Act requires publicly listed U.S. companies to determine whether their products contain 3TG minerals. If they do, companies must:
- Conduct a reasonable country-of-origin inquiry to determine whether minerals originate in the Democratic Republic of Congo (DRC) or adjoining countries
- Perform supply chain due diligence if the origin is uncertain or linked to these regions
- File an annual Specialized Disclosure Report (Form SD) with the U.S. Securities and Exchange Commission (SEC)
- Publicly disclose their due diligence practices and findings
The SEC enforces this regulation. Non-compliance can lead to legal risks, reputational damage, and loss of business opportunities.
EU Conflict Minerals Regulation (EU) 2017/821
The EU Conflict Minerals Regulation takes a broader, upstream approach. It applies to EU importers of 3TG minerals and metals, regardless of company size or listing status. Key requirements include:
- Conducting due diligence for sourcing from conflict-affected and high-risk areas worldwide
- Establishing supply chain policies and risk management systems
- Implementing mitigation strategies where risks are identified
- Undergoing independent third-party audits of smelters and refiners
Enforcement is handled by individual EU Member States. The regulation emphasizes transparency, risk mitigation, and independent verification.
Key Differences: Dodd-Frank vs. EU Regulation 2017/821
How Companies Manage CMRT at Scale
Managing CMRT effectively requires more than sending spreadsheets to suppliers.
Companies typically implement structured workflows to:
- Identify in-scope suppliers
- Distribute CMRT templates simultaneously
- Track response rates with automated reminders
- Consolidate supplier responses
- Validate smelters against RMI databases
- Generate audit-ready documentation
Modern compliance platforms like eliminate manual consolidation and enable centralized oversight of both CMRT and EMRT reporting within one system.
How CDX Simplifies CMRT Reporting
Collect, validate, and consolidate supplier CMRTs in one centralized system. CDX helps you manage responsible minerals reporting efficiently and with confidence.