On April 27, 2022, the Responsible Minerals Initiative, RMI, released the newest version (v. 6.2) of the Conflict Minerals Reporting Template, CMRT. This is the 24th version, the 4th release at version 6, and the first update since CMRT v. 6.1, released on April 28, 2021.
The major updates to this version of the CMRT are the correction of bugs and errors, regular maintenance updates to the smelter lists, and translation improvements in the template.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found here. The next update to the CMRT is anticipated for Spring of 2023.
The new CMRT is a tool for individuals collecting conflict minerals 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 That is to say, declaration of conflict minerals use via CMRT v. 5.01 potentially contains out-of-date information when compared to a current CMRT (v. 6.2).
The new CMRT may be used as a mechanism for gathering updated conflict minerals data and improving overall data collection from the supply chain. 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 for the SEC that will show data received in the current year after April 27, 2022. This will demonstrate the necessary due diligence that is a hallmark of reasonable country of origin inquiry (RCOI). Also, any effort in communicating expectations around this requirement to a supplier can be similarly used in the Form SD.
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Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including Conflict Minerals updates.