RMI’s Cobalt Reporting Template: A Pilot

The Responsible Minerals Initiative, RMI, has launched a pilot program to gather information on global cobalt supply chains. This pilot runs from March 1 until August 31, 2018.

Cobalt is expected to see a rise in demand due to its applications in battery technologies for mobile phones, laptops, and electric/hybrid vehicles.

The Democratic Republic of Congo, DRC, is the world’s leading producer of cobalt. Via the Conflict Minerals Act, tin, tantalum, tungsten, and gold from DRC have been tracked via the RMI’s Conflict Minerals Reporting Template (CMRT). While cobalt mining is not cited as being a source for conflict in the region, there have been reports of unsafe mining practices and the use of child labor.

Based upon the cobalt pilot, your company may ask or be asked by customers about the use of cobalt and cobalt sourcing practices. To learn more about the questions please find the RMI’s cobalt reporting template (CRT) at http://www.responsiblemineralsinitiative.org/emerging-risks/cobalt-reporting-template/

After the pilot period, there will be a feedback period from September 1 to October 1, 2018 where users may submit feedback via survey to the RMI. Results of the pilot will be reviewed by RMI with a decision on the continuation of the CRT by December 2018.


Using GDX to Get Ahead of RoHS 2 + Phthalates

In June of 2015, four phthalates were added to Annex II of the RoHS Directive. The European Commission selected an enforcement date of July 22, 2019 (2021 for Categories 8 & 9). Electrical and electronic equipment containing the phthalates will not be placed on the market in EU after the enforcement date. For more details on the added substances and the enforcement dates see this link.

Because of the additional substances, it is important to update and gather new RoHS compliance documentation at the “RoHS 2 + phthalates” level in order to maintain compliance and access to the EU markets. Green Data Exchange (GDX) has informed suppliers and educated in-house compliance teams about the needed updates to the RoHS Directive. Many suppliers have already updated their RoHS declarations in GDX to account for phthalates and are adding more data daily. In using GDX, you are able to ensure your compliance to RoHS 2 + phthalates well ahead of the enforcement dates.

On the term “RoHS 2 + Phthalates”

Q Point has adopted the title of “RoHS 2 + phthalates” when referring to the RoHS (recast) Directive 2011/65/EU + Directive 2015/863 which amends Annex II to include the four phthalates.

Some organizations have referred to the amended version of RoHS containing phthalates as “RoHS 3.” We maintain this is a misnomer as the RoHS Directive coming into force in 2019 maintains 2011/65/EU. The only distinction is the amended Annex II of 2011/65/EU which was done by the passing of ED 2015/863.

If you have any questions on RoHS 2 + phthalates, would like to learn about GDX, or to request a demo, please visit our website or email us at gdx_support@qpointtech.com.

RMI Publishes CMRT Version 5.11

On April 27, the Responsible Minerals Initiative, RMI, released the newest version (v. 5.11) of the Conflict Minerals Reporting Template, CMRT. This is the 19th version, the fourth release at version 5, and the first update since CMRT v. 5.10, released on December 1, 2017.

The major updates to this version of the CMRT are the correction of bugs and errors, enhancements that do not conflict with IPC 1755, 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 November 2018.

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. Q Point adopts the stance that data provided from the latest version of the CMRT indicates updated information. That is to say, a CMRT v. 5.01 contains potentially out-of-date information when compared to a current CMRT (v. 5.11).

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 27, 2018. 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.

The RMI has also released a pilot program for the collection of data pertaining to Cobalt. A follow-up article will focus specifically on this new effort and its implications.