On May 26, 2023, the Responsible Minerals Initiative, RMI, released the newest version (v. 6.31) of the Conflict Minerals Reporting Template, CMRT. This is the 27th version, the 7th release at version 6, and the first update since CMRT v. 6.3, released on May 5, 2023.
The updates to this version of the CMRT are minor revisions to correct reported issues including those related to “Declaration”, “Smelter List”, and “Smelter Look-up” tabs on CMRT 6.3.
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 2024.
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 That is to say, declaration of conflict minerals use via CMRT v. 5.01 potentially contains out-of-date information when compared to a current CMRT (v. 6.31).
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 May 26, 2023. 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.
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.
Please continue to check the Q Point Technology Blog for recent news on regulatory changes, including Conflict Minerals updates.