CMRT 6.22

On May 11th, 2022, the Responsible Minerals Initiative (RMI) released version 6.22 of the Conflict Minerals Reporting Template: CMRT 6.22.

What has Changed with CMRT 6.22?

The Previous Edition

The previous released version 6.2 has lasted a few weeks and was replaced by the Conflict Mineral Reporting Template 6.22. Among other things, CMRT 6.2 included a few improvements such as:

Modifications of the Excel form; and
Update of smelters’ list and their identification (CID).

Minor Corrections with CMRT 6.22

CMRT 6.22 reveals to be a correction of 6.2. Indeed, RMI refers to minor improvements to the Product List tab of the Excel CMRT.

When to Use CMRT 6.22?

First of all, as a manufacturer using tin, tantalum, tungsten, or gold (known under the acronym 3TGs) in your products, you may start using CMRT 6.22 to audit your supply chain.
Nevertheless, RMI indicates that editions 6.01 and higher remain valid. Therefore, your supplier can keep sending you these recent CMRT versions until RMI releases a new version, like CMRT 6.3 or 7.0.

Why does RMI Regularly Update CMRT?

RMI is an organization responsible for equipping impacted industries with Conflict Minerals auditing tools. Hence their free CMRT Excel standard.

Since the smelters’ sector constantly evolves, RMI regularly revises the list of active smelters on the CMRT. Other examples of amendments include:

Revisions of audited clauses, like the question about conflict-affected and high-risk areas (CAHRA) per the European Union (EU) Regulation 2017-821; or
Improvement of the form and translations

You can find more details about previous CMRTs in these blog posts:

What Major Amendments to the CMRT should we Expect?

Sadly, conflicts arise virtually anywhere and can jeopardize the minerals trade. For example, these geopolitical considerations are affecting Eastern Europe and Ukraine.

As a result, major markets like the USA and the EU can decide to increase surveillance of other strategical minerals, such as:

cobalt;
mica; or
rare earth elements.

Additionally, the USA may target other high-risk areas than the Democratic Republic of the Congo (DRC) and its surrounding countries.

What is the Legal Basis for CMRT 6.22?

SEC Obligations in the USA

Since the Obama Administration, US public companies under the Securities and Exchange Commission (SEC) must declare their conflict minerals Due Diligence status. Such obligations stem from the so-called Dodd-Frank act.

Conflict Minerals Reporting in the EU

The European Union Regulation 2017/821 triggers 3TGs auditing and reporting from conflict-affected and high-risk areas.

What Companies Should Use CMRT 6.22?

In short, conflict minerals reporting impacts companies that:

Directly or indirectly source 3TGs to manufacture goods;
Are under legal or contractual obligations to perform due diligence of 3TGs sourcing.

Beyond CMRT 6.22

On the other hand, other social and environmental obligations are likely to impact manufacturers, depending on their type of industry. Examples of other compliance obligations are:

RoHS and WEEE for electrical and electronic equipment;
REACH-SVHC, California Proposition 65, POP, and TSCA-PBT for most fabricated goods.
Human trafficking ban policies.

Are you unsure how to assess your supply chain against conflict minerals? Would you like an expert to verify your corporate Due Diligence processes, policies, and CMRTs? Contact Enviropass and request a free consultation.

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