RMI (Formerly CFSI) Publishes CMRT Version 5.10

On December 1, the Responsible Minerals Initiative (RMI), formerly the Conflict Free Sourcing Initiative (CFSI), released the newest version (v. 5.10) of the Conflict Minerals Reporting Template, CMRT. This is the 18th new release, the third release at version 5, and the most recent update since CMRT v.5.01, released on June 21, 2017.
The major updates to the CMRT include corrections to all bugs and errors, enhancements in accordance with IPC-1755, updated ISO short names for countries, states, and provinces, updates to the “Smelter Reference List” and “Standard Smelter List,” and a change to .xlsx format.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for May 2018.
The new CMRT provides an opportunity for corporations and individuals collecting CMRT data as part of their due diligence surrounding a reasonable country of origin inquiry (RCOI) for SEC Reporting. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 5.10).
Corporations and individuals may use the new CMRT as a mechanism for gathering updated conflict minerals data and improving overall data collection from their suppliers. Alerting suppliers to the new CMRT may lead to a discussion that sets expectations for routine updates and the use of the latest CMRT version. Exclusive use of the new CMRT will produce Form SD filings with the SEC that will show data received in the current year after December 1, 2017. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating a requirement and expectations to a supplier can be similarly used in the Form SD.