Hello. This is MDSKorea.
When handling automotive and electronic components, you often receive requests from customers to submit "Responsible Minerals Reports (CMRT, EMRT, etc.)."
From the perspective of a component manufacturer with no direct connection to mining, these demands can feel somewhat overwhelming. In this article, we clearly summarize what responsible minerals are and what specific procedures need to be followed in practice.
Overview
The core of responsible minerals compliance lies in transparently tracking the origin of minerals throughout the entire supply chain. The international standard for this is the OECD Due Diligence Guidance1), and the Reporting Templates by RMI2) have standardized this guidance for smooth practical application.
1) OECD's 5-step process for identifying, mitigating, and reporting supply chain risks
2) Responsible Minerals Initiative: The organization that created standardized reporting templates such as CMRT and EMRT
Key Takeaways
Q1. What is the background behind companies being required to report mineral origins?
Mineral origin reporting began as a movement to address human rights violations and the funding of armed groups in certain conflict areas, such as the Democratic Republic of the Congo (DRC).
To prevent the use of unethically mined resources, the US Dodd-Frank Act in 2010 and the European Union (EU) Conflict Minerals Regulation in 2017 were enacted consecutively.
Consequently, global companies are obligated to verify and disclose whether the minerals contained in their products are free from human rights abuses. You can understand customers demanding mineral origin reports from suppliers within the supply chain as a chain reaction to fulfill these global supply chain regulations and social responsibilities.
Q2. Then, what is the difference between conflict minerals and responsible minerals?
Responsible Minerals is the highest-level concept encompassing conflict minerals, extended minerals, and additional minerals altogether. They are managed through dedicated reporting templates depending on the mineral type, as outlined below:
Responsible Minerals: The most comprehensive, overarching concept demanding social responsibility throughout the mining and processing stages.
Conflict Minerals (3TG): Refers to four specific minerals—Tin, Tantalum, Tungsten, and Gold—and is reported using the CMRT3) template.
Extended Minerals: Includes six minerals—Cobalt, Lithium, Nickel, Copper, Natural Mica, and Natural Graphite—and is managed through the EMRT4) template.
Additional Minerals: Minerals not covered by CMRT and EMRT. It provides 18 basic minerals, and users can specify up to 10 additional minerals based on their needs. Additional minerals are managed through the AMRT5) template.
3) Conflict Minerals (3TG) Reporting Template
4) Extended Minerals Reporting Template (Cobalt, Natural Mica, Copper, Natural Graphite, Lithium, Nickel)
5) A template where users can directly designate and manage 10 additional types of minerals besides the 18 basic types.
Q3. Are component companies that do not directly mine these minerals also subject to reporting?
Yes, as you belong to the Downstream6) sector of the supply chain, you hold a reporting role. RMI defines the stages from after the smelter or refiner7) to the end-user as downstream.
Therefore, component manufacturers do not conduct direct due diligence at mines, but rather communicate with Tier 1 suppliers to identify and verify information on the smelters and refiners where minerals are processed into commercial quality.
6) from the post-smelter/refiner stage to the end user
7) Key points in the supply chain where minerals are processed into commercial-grade quality
Q4. Can this be replaced by existing MSDS data?
The two documents have entirely different purposes of issuance, so they cannot substitute for each other.
MSDS: A document intended to inform about the hazards of chemical substances; minerals below the regulatory threshold may not be listed.
CMRT/EMRT: The primary purpose is to identify and track the smelters and refiners that all minerals pass through. Therefore, if a relevant mineral is contained in the product, regardless of its content percentage, it is practically crucial to obtain smelter information from the supplier.
Q5. What standards does the international community require for corporate responsible minerals management?
The core of global supply chain regulation is the 'Due Diligence Guidance for Responsible Supply Chains' published by the OECD (Organization for Economic Co-operation and Development).
The OECD presents the following 5-Step Framework as an international standard so that companies can manage their supply chains transparently while protecting human rights and the environment:
Establish strong company management systems
Identify and assess risks in the supply chain
Design and implement a strategy to respond to identified risks
Carry out independent third-party audit of smelter/refiner's due diligence practices
Report annually on supply chain due diligence
Q6. If the collected data is incomplete, will immediate disadvantages occur?
Omissions or inconsistencies in data do not immediately translate into critical risks. You should understand this as a red flag8) indicating that additional verification and action are required, and respond according to the following procedures:
Factual Investigation: Upon discovering a red flag, proceed with additional information collection regarding the target.
Risk Mitigation Request: Continuously request suppliers to take actions that can substantially mitigate the identified risks.
Continuous Tracking & Management: If a refiner is not clearly identified, establish a long-term risk management plan to improve data quality sequentially.
8) A signal that triggers enhanced due diligence, requiring additional verification
Conclusion
Rather than immediately submitting 100% perfect data, the core of responsible minerals compliance is proving the transparent process itself—identifying risks and continuously making improvements based on the OECD 5-Step Due Diligence Framework.
MDSKorea will always strive to deliver useful and valuable information. Thank you.
[Glossary]
| Term | Description |
|---|
Conflict Minerals (3TG) | Minerals extracted in conflict zones, including Tin, Tantalum, Tungsten, and Gold. |
Extended Minerals | Minerals other than 3TG, such as Cobalt, Lithium, and Nickel, that raise concerns regarding human rights violations in the supply chain. |
RMI | Responsible Minerals Initiative; the organization that established standardized reporting templates such as CMRT and EMRT. |
| CMRT | Conflict Minerals (3TG) Reporting Template. |
| EMRT | Extended Minerals Reporting Template (includes Cobalt, Natural Mica, Copper, Natural Graphite, Lithium, and Nickel). |
| AMRT | A template where users can directly designate and manage up to 10 additional minerals in addition to the 18 basic minerals. |
Smelter / Refiner | Key points in the supply chain where minerals are processed into commercial-grade quality. |
Downstream | from the post-smelter/refiner stage to the end user
|
Due Diligence | The OECD's 5-step process for identifying, mitigating, and reporting risks in the supply chain. |
Red Flag | A warning signal that requires additional verification and triggers enhanced due diligence. |
[Source]
Hello. This is MDSKorea.
When handling automotive and electronic components, you often receive requests from customers to submit "Responsible Minerals Reports (CMRT, EMRT, etc.)."
From the perspective of a component manufacturer with no direct connection to mining, these demands can feel somewhat overwhelming. In this article, we clearly summarize what responsible minerals are and what specific procedures need to be followed in practice.
Overview
The core of responsible minerals compliance lies in transparently tracking the origin of minerals throughout the entire supply chain. The international standard for this is the OECD Due Diligence Guidance1), and the Reporting Templates by RMI2) have standardized this guidance for smooth practical application.
1) OECD's 5-step process for identifying, mitigating, and reporting supply chain risks
2) Responsible Minerals Initiative: The organization that created standardized reporting templates such as CMRT and EMRT
Key Takeaways
Q1. What is the background behind companies being required to report mineral origins?
Mineral origin reporting began as a movement to address human rights violations and the funding of armed groups in certain conflict areas, such as the Democratic Republic of the Congo (DRC).
To prevent the use of unethically mined resources, the US Dodd-Frank Act in 2010 and the European Union (EU) Conflict Minerals Regulation in 2017 were enacted consecutively.
Consequently, global companies are obligated to verify and disclose whether the minerals contained in their products are free from human rights abuses. You can understand customers demanding mineral origin reports from suppliers within the supply chain as a chain reaction to fulfill these global supply chain regulations and social responsibilities.
Q2. Then, what is the difference between conflict minerals and responsible minerals?
Responsible Minerals is the highest-level concept encompassing conflict minerals, extended minerals, and additional minerals altogether. They are managed through dedicated reporting templates depending on the mineral type, as outlined below:
Responsible Minerals: The most comprehensive, overarching concept demanding social responsibility throughout the mining and processing stages.
Conflict Minerals (3TG): Refers to four specific minerals—Tin, Tantalum, Tungsten, and Gold—and is reported using the CMRT3) template.
Extended Minerals: Includes six minerals—Cobalt, Lithium, Nickel, Copper, Natural Mica, and Natural Graphite—and is managed through the EMRT4) template.
Additional Minerals: Minerals not covered by CMRT and EMRT. It provides 18 basic minerals, and users can specify up to 10 additional minerals based on their needs. Additional minerals are managed through the AMRT5) template.
3) Conflict Minerals (3TG) Reporting Template
4) Extended Minerals Reporting Template (Cobalt, Natural Mica, Copper, Natural Graphite, Lithium, Nickel)
5) A template where users can directly designate and manage 10 additional types of minerals besides the 18 basic types.
Q3. Are component companies that do not directly mine these minerals also subject to reporting?
Yes, as you belong to the Downstream6) sector of the supply chain, you hold a reporting role. RMI defines the stages from after the smelter or refiner7) to the end-user as downstream.
Therefore, component manufacturers do not conduct direct due diligence at mines, but rather communicate with Tier 1 suppliers to identify and verify information on the smelters and refiners where minerals are processed into commercial quality.
6) from the post-smelter/refiner stage to the end user
7) Key points in the supply chain where minerals are processed into commercial-grade quality
Q4. Can this be replaced by existing MSDS data?
The two documents have entirely different purposes of issuance, so they cannot substitute for each other.
MSDS: A document intended to inform about the hazards of chemical substances; minerals below the regulatory threshold may not be listed.
CMRT/EMRT: The primary purpose is to identify and track the smelters and refiners that all minerals pass through. Therefore, if a relevant mineral is contained in the product, regardless of its content percentage, it is practically crucial to obtain smelter information from the supplier.
Q5. What standards does the international community require for corporate responsible minerals management?
The core of global supply chain regulation is the 'Due Diligence Guidance for Responsible Supply Chains' published by the OECD (Organization for Economic Co-operation and Development).
The OECD presents the following 5-Step Framework as an international standard so that companies can manage their supply chains transparently while protecting human rights and the environment:
Establish strong company management systems
Identify and assess risks in the supply chain
Design and implement a strategy to respond to identified risks
Carry out independent third-party audit of smelter/refiner's due diligence practices
Report annually on supply chain due diligence
Q6. If the collected data is incomplete, will immediate disadvantages occur?
Omissions or inconsistencies in data do not immediately translate into critical risks. You should understand this as a red flag8) indicating that additional verification and action are required, and respond according to the following procedures:
Factual Investigation: Upon discovering a red flag, proceed with additional information collection regarding the target.
Risk Mitigation Request: Continuously request suppliers to take actions that can substantially mitigate the identified risks.
Continuous Tracking & Management: If a refiner is not clearly identified, establish a long-term risk management plan to improve data quality sequentially.
8) A signal that triggers enhanced due diligence, requiring additional verification
Conclusion
Rather than immediately submitting 100% perfect data, the core of responsible minerals compliance is proving the transparent process itself—identifying risks and continuously making improvements based on the OECD 5-Step Due Diligence Framework.
MDSKorea will always strive to deliver useful and valuable information. Thank you.
[Glossary]
Conflict Minerals (3TG)
Extended Minerals
RMI
Smelter / Refiner
Downstream
Due Diligence
Red Flag
[Source]
Due Diligence
CMRT (Conflict Minerals Reporting Template)
EMRT (Extended Minerals Reporting Template)
AMRT (Additional Minerals Reporting Template)