On May 13, 2020, the Responsible Minerals Initiative, RMI, released the newest version (v. 6.0) of the Conflict Minerals Reporting Template, CMRT. This is the 21st version, the 1st release at version 6, and the first update since CMRT v. 5.12, released on April 26, 2019.
The major updates to this version of the CMRT are the correction of bugs and errors, conformance to IPC 1755 in support of EU Conflict Minerals Regulation, addition of a new question 4 and the removal of question C, updates to the ISO short names for countries, states, and provinces, and regular maintenance updates to the smelter lists.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.responsiblemineralsinitiative.org. The next update to the CMRT is anticipated for Spring of 2021.
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. RMI recommends the use of CMRT version 5.01 or newer for this year and version 6.0 for subsequent years. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, declaration of 3TG use via CMRT v. 5.01 potentially contains out-of-date information when compared to a current CMRT (v. 6.0).
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 April 26, 2019. 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.
Green Data Exchange (GDX) provides a real-time environment, with access to the latest compliance information from your suppliers. Connect with your suppliers and parts to get the latest compliance data, like the new conflict minerals reporting template, delivered to you. Learn more about GDX today at http://www.qpointtech.com/about-gdx.html.
Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including Conflict Minerals updates.