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.

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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.

RMI (Formerly CFSI) Publishes CMRT Version 5.10

On December 1, the Responsible Minerals Initiative (RMI), formerly the Conflict Free Sourcing Initiative (CFSI), released the newest version (v. 5.10) of the Conflict Minerals Reporting Template, CMRT. This is the 18th new release, the third release at version 5, and the most recent update since CMRT v.5.01, released on June 21, 2017.
The major updates to the CMRT include corrections to all bugs and errors, enhancements in accordance with IPC-1755, updated ISO short names for countries, states, and provinces, updates to the “Smelter Reference List” and “Standard Smelter List,” and a change to .xlsx format.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for May 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. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 5.10).
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 December 1, 2017. 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.

CFSI Publishes CMRT Version 5.01

On June 21, the Conflict Free Sourcing Initiative, CFSI, released the newest version (v. 5.01) of the Conflict Minerals Reporting Template, CMRT. This is the 17th new release, the second release at version 5, and the first update since CMRT v.5.0, released on May 12, 2017.
The major update to the CMRT is the correction of bugs and errors on the Checker tab.
Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for November 2017.
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. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 5.01).
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 June 21, 2017. 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.

CFSI Publishes CMRT Version 5.0

On May 12, the Conflict Free Sourcing Initiative, CFSI, released the newest version (v. 5.0) of the Conflict Minerals Reporting Template, CMRT. This is the 16th new release, the first release at version 5, and the first update since CMRT v.4.20, released on November 30, 2016.

Updates to CMRT v.5.0 include corrections to bugs and errors, conformance to IPC 1755 in the question wording, removal of company level question G (“Do you request smelter names from your suppliers?”), the addition of ISO country codes and state/province codes on the smelter list tab, renaming the “Smelter Reference List” as the “Smelter Look-up,” and updates and revisions to the Standard Smelter List and Smelter Look-up List.

Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for November 2017.
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. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 5.0).

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 May 12, 2017. 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.

European Union Releases Details on EU Conflict Minerals Regulation

On November 22, The EU agreed on a Conflict Mineral Regulation framework. The regulation seeks to inhibit import and sale of minerals and ores that are used to fund armed conflict and infringe upon basic human rights.

Importers of Tin, Tantalum, Tungsten, and Gold (3TG) will be required to review and conduct due diligence upon their supply chain beginning in 2021. Also beholden to the regulation are smelters and refiners of 3TG.

Exempted from the regulation is the import of finished products that may contain 3TG.

Major differences between the EU and US version of the Conflict Minerals regulations include the exemption of imported finished goods by the EU version and an increased scope of where the minerals may have been obtained. EU Conflict Minerals requires all 3TG whereas US Conflict Minerals Act addresses 3TG from the Democratic Republic of Congo and its nine neighboring countries.

As the phase-in period begins for EU Conflict Minerals, please check back with this blog for any and all pertinent updates and changes.

CFSI Publishes CMRT Version 4.20

On November 30, the Conflict Free Sourcing Initiative, CFSI, released the newest version (v. 4.20) of the Conflict Minerals Reporting Template, CMRT. This is the 15th new release, the sixth release at version 4, and the first update since CMRT v.4.10, released on April 29, 2016.

Updates to CMRT v.4.20 include corrections to bugs and errors, updated smelter lists, IPC 1755 compatible enhancements to the instructions page and an update to ISO short names for countries, and finally translational improvements for all updated instructions and definitions.

Updated smelter lists and smelter details (along with the latest version of the CMRT) may be found at http://www.conflictfreesourcing.org. The next update to the CMRT is anticipated for April 2017.

The new CMRT provides a unique 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. 4.01(b) contains older, and perhaps out of date, information when compared to a current CMRT (v. 4.20).

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 November 30, 2016. 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.