What Is the Extended Minerals Reporting Template (EMRT)?

Article Highlights:

• The EMRT is designed to cover not just 3TG minerals but also cobalt and mica, which are increasingly recognized for their potential links to similar ethical concerns. 
• The Conflict Minerals Reporting Template (CMRT) and the Extended Minerals Reporting Template (EMRT) are both used for supply chain reporting, but they differ in their scope and the types of minerals they cover. 
• You should have your suppliers complete the Extended Minerals Reporting Template (EMRT), which includes questions about the source and smelters/refiners of the minerals.
• Z2Data has several solutions to help reach compliance with both CMRT or EMRT requirements, depending on the needs of your company. 

In today’s global supply chain, the ethical sourcing of minerals has become a critical concern for companies across various industries. Several key tools have been developed to address these concerns, including the EMRT. In this article we take a look at the more popular and well known CMRT, its extension, EMRT, and how both reporting templates work together to give you a comprehensive mineral reporting framework. 

What Do CMRT and EMRT Mean?

The Conflict Minerals Reporting Template (CMRT) is a standardized tool used by companies to collect and report information related to the sourcing of minerals. The CMRT is particularly important for those raw materials considered to be "conflict minerals,” including tin, tantalum, tungsten, and gold (often referred to as 3TG). These minerals are sourced from regions that may be affected by conflict, and their extraction and trade can sometimes contribute to human rights abuses. 

The EMRT is an extension of the Conflict Minerals Reporting Template (CMRT) and is designed to cover not just 3TG minerals but also cobalt and mica, which are increasingly recognized for their potential links to similar ethical concerns. The template helps companies gather information from their supply chains to ensure that the minerals they use are sourced responsibly and in compliance with regulations such as the U.S. Dodd-Frank Act and the European Union's Conflict Minerals Regulation.

Who Does EMRT Apply To?

The Extended Minerals Reporting Template (EMRT) primarily applies to companies that are involved in industries where minerals like tin, tantalum, tungsten, gold (3TG), cobalt, and mica are used. These companies are typically part of supply chains that involve the extraction, processing, manufacturing, or sale of products containing these minerals. The EMRT is relevant to manufacturers, suppliers, and downstream companies, including retailers and brand owners, who use the information collected to ensure that the products they sell are compliant with responsible sourcing regulations and commitments.

CMRT vs. EMRT: What's the Difference?

The Conflict Minerals Reporting Template (CMRT) and the Extended Minerals Reporting Template (EMRT) are both tools used for supply chain reporting. They differ, however, in their scope and the types of minerals they cover. The CMRT is specifically designed to address the reporting of "conflict minerals”—specifically tin, tantalum, tungsten, and gold (3TG). These minerals are of concern due to their potential links to conflict financing, especially in regions such as the Democratic Republic of the Congo and surrounding regions in Africa. 

The EMRT, meanwhile, extends beyond the scope of the CMRT by including additional minerals like cobalt and mica. Cobalt and mica are also associated with human rights concerns, such as child labor and unsafe working conditions, particularly within the processes involved in artisanal mining. The primary purpose of the CMRT is to help companies comply with regulations such as the U.S. Dodd-Frank Act (Section 1502), which requires publicly traded companies to report on the source of 3TG minerals in their supply chains. The EMRT serves a similar purpose, except with a broader focus. The new reporting regulation helps companies conduct due diligence and report on the sourcing of not only 3TG minerals but also cobalt and mica, addressing a wider range of ethical and regulatory concerns. 

The EMRT represents an evolution of the CMRT, developed to address the need for more comprehensive mineral reporting and reflecting broader concerns about supply chain transparency and ethical sourcing.

How Can Companies Successfully Complete the EMRT?

Filling out the Extended Minerals Reporting Template (EMRT) involves several steps that require accurate and detailed information from your supply chain. You can download the latest version of the EMRT from the Responsible Minerals Initiative (RMI) website. The template has a few key standard fields:

• Company Information: Basic details about your company.
• Declaration: Information on the scope of the reporting, including the specific minerals being reported (3TG, cobalt, mica).
• Mineral Sourcing Information: Details on the smelters and refiners in your supply chain.
• Product List: List of products or components that contain the relevant minerals.
• Smelter and Refiner Information: Identification of smelters and refiners used in your supply chain.

This information comes from due diligence data collected from your suppliers. Obtaining it involves reaching out to all relevant suppliers and asking them to provide information on the source of the 3TG, cobalt, and mica in the products they supply to you. If your company is a supplier, you may need to provide the completed EMRT to your customers. You will also want to keep a record of the completed EMRT and the data used to populate it. This is important due diligence evidence for future audits or reporting cycles. 

As with most regulations, you will also need to review and update your supply chain due diligence processes on a regular basis. Engage with suppliers early and often to improve the accuracy and comprehensiveness of your reports over time.

How Do You Know If You’re Sourcing From a Conflict-Affected Area? 

To determine if you are sourcing from conflict-affected or high-risk areas, you'll need to conduct thorough due diligence on your supply chain. Some organizations, like the Responsible Minerals Initiative (RMI) or the European Union, provide lists or databases of regions considered conflict-affected or high-risk for mineral sourcing. These lists are regularly updated and can be used as a reference. In addition, you should have your suppliers complete the Extended Minerals Reporting Template (EMRT), which includes questions about the source and smelters/refiners of the minerals. You should also cross-check the information provided by your suppliers against recognized lists of conflict-free smelters and refiners, such as those audited and recognized by the RMI. 

Finally, it never hurts to keep up with geopolitical developments in regions where your minerals are sourced. Areas experiencing armed conflict, political instability, or widespread human rights abuses may be considered high-risk—either now or in the near future. 

What Resources Can I Utilize for EMRT?

You can engage with industry experts or specialized consulting firms that monitor conflict areas and human rights issues related to mining. You can also use risk mapping tools to identify whether any part of your supply chain is connected to conflict-affected or high-risk areas. These tools often include databases that track risks by region or industry. It’s also common for companies to conduct audits or assessments of suppliers—especially those located in or near known conflict zones—to evaluate their sourcing practices and the transparency of their supply chains. 

The Responsible Minerals Assurance Process (RMAP) by the RMI lists smelters and refiners that have been audited and found to conform to responsible sourcing standards. Using smelters from this list can reduce the risk of sourcing from conflict-affected areas. The RMI also provides a Conflict-Affected and High-Risk Areas (CAHRA) tool that helps companies identify if their sourcing regions fall under these categories. However, the most important measure you can take is to monitor your supply chain for any changes that might affect the risk status of the areas from which you source. Conflict situations can evolve, so staying informed is key. Training your suppliers on responsible sourcing practices and the importance of transparency, as well as encouraging regular communication, can also be advantageous steps in remaining vigilant and responsive to these issues.

How Can Z2Data Help?

Z2Data has several solutions to help reach compliance with both CMRT or EMRT requirements, depending on the needs of your company. Z2Data’s Compliance Manager solution can serve as a central platform for your due diligence efforts, contacting suppliers on your behalf, and helping you create your own EMRT template in order to adhere to responsible sourcing practices. 

Additionally, Z2Data’s supplier insights part-to-site mapping gives you insight into where your parts are manufactured around the world, providing a clear, actionable view of how major events–including armed conflicts–affect your supply chain.