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Conflict Minerals CMRT Supplier Tracking Worksheet

A conflict minerals program lives or dies on follow-up: who has sent a CMRT, which version, and whether their smelters are on the right lists. This worksheet gives you a single place to track it and export a clean record.

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Supplier	Part or commodity	3TG in scope	CMRT status	CMRT version	Smelters listed	RMAP conformant or active	Conformant share	Follow-up due
							90.5%
							100%
							0%
							66.7%
							0%

Total smelters listed

Total conformant

Suppliers tracked

Overall conformant smelter share

89.2%

Conformant or active smelters as a share of all smelters listed across received CMRTs.

Use one row per supplier and commodity. Conformant means conformant or active on the RMI Responsible Minerals Assurance Process list at the time of your review. Always re-check the smelter list before relying on it for a Form SD filing.

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How to use the worksheet

Add one row per supplier and covered commodity. Pick the 3TG metal in scope (tin, tantalum, tungsten, gold), set the CMRT status, and record the template version the supplier used. Enter the number of smelters or refiners the supplier listed and how many are conformant or active in the RMAP. The sheet computes a conformant share per row and an overall share. Set a follow-up date for anything overdue or expired, then export to Excel to share with procurement or your reporting team.

Start with every supplier whose parts may contain tin, tantalum, tungsten or gold
Mark suppliers with no declared 3TG so the decision is documented
Keep the CMRT version, since older versions miss newer questions
Review expired or overdue rows monthly during the reporting season

The method behind it

Section 1502 of the Dodd-Frank Act requires SEC registrants whose products contain necessary 3TG to perform a reasonable country of origin inquiry and, where needed, due diligence, then file Form SD by 31 May each year. Most companies use the RMI Conflict Minerals Reporting Template to collect supplier declarations and smelter lists, and align due diligence to the OECD guidance. The smelter or refiner is the choke point, which is why the conformant share is the key number. Customers outside the SEC population often ask for the same CMRT through their supply chain.

Reading the result and common mistakes

A high overall share is good, but a single supplier with zero smelters listed or a declaration of unknown is a gap, not a pass. Look at each low row and decide whether to escalate, request a corrected CMRT, or switch source. Treat the conformant share as a monitoring metric, not a compliance verdict.

Accepting a blank or partly completed CMRT as received
Tracking the company level only when the answer is product specific
Not re-checking smelter status after the template date
Forgetting 3TG in plating chemicals, solder and alloys

Frequently Asked Questions

What is a CMRT?

The Conflict Minerals Reporting Template is a standard spreadsheet maintained by the Responsible Minerals Initiative. A supplier uses it to declare whether tin, tantalum, tungsten or gold is in their products and to list the smelters or refiners in their supply chain.

Who has to file Form SD?

Companies that file reports with the SEC and manufacture or contract to manufacture products where necessary 3TG are present must conduct the inquiry and file Form SD each year. Suppliers outside the SEC population are usually asked for a CMRT by their customers.

What does RMAP conformant mean?

It means the smelter or refiner has undergone an audit under the Responsible Minerals Assurance Process and meets the standard. Active means it has committed to an audit. Check the current RMI lists, since status changes over time.

Does this replace the CMRT itself?

No. The CMRT is the supplier declaration. This worksheet is your internal tracker that records who responded, which version, and the quality of the smelter data, so you can chase gaps and keep an audit trail.

If your supplier declarations live in an ERP vendor record and a shared drive, we can help pull them into one governed view that your team queries on-prem.

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