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Article Highlights:
Launched in late 2022, the Additional Minerals Reporting Template (AMRT) is the newest and most flexible of the three, and it exists to capture due diligence data on minerals that don't fit neatly into CMRT or EMRT.
AMRT requests from original equipment manufacturers (OEMs) sourcing from direct and sub-tier suppliers have surged over the past eighteen months, particularly in industries like automotive, electronics, and aerospace. Even though there haven’t been any significant regulatory changes, plenty of suppliers are navigating new due diligence obligations.
Every time a new mineral gets flagged as strategically important—whether it’s an REE tied to defense manufacturing or a mineral essential to battery production—there's a reasonable chance it ends up as a candidate for AMRT reporting.
If you work in trade compliance or supply chain due diligence, you might have noticed that your customers are asking for more than they used to. A few years ago, a request for conflict minerals reporting meant one thing: a completed CMRT covering tin, tantalum, tungsten, and gold, otherwise known as the 3TG conflict minerals. Now, though, it's not unusual to get that request bundled with an EMRT, an AMRT, or both. If you're wondering whether something changed in the regulations, the simplest answer is no—no new law has expanded conflict minerals reporting requirements in the U.S.
But the Additional Minerals Reporting Template, or AMRT, is quietly imposing more due diligence obligations on many manufacturers. That’s because, in the realm of compliance, it’s not just about new regulations passed by the U.S., the European Union, or China. It’s also about the expectations and demands of customers. And that’s a distinction that’s worth unpacking, because it changes how companies should be building out their compliance programs for 2026 and beyond.
What AMRT Actually Is
The Responsible Minerals Initiative maintains three standardized templates that companies use to collect supply chain data from suppliers:
The Conflict Minerals Reporting Template (CMRT)
The Extended Minerals Reporting Template (EMRT)
The Additional Minerals Reporting Template (AMRT)
Each of these frameworks covers a different scope of minerals. CMRT is the original and the one most people are referring to when they talk about conflict minerals reporting. CMRT covers tin, tantalum, tungsten, and gold (3TG). The next template, EMRT, picks up where CMRT leaves off, expanding into cobalt, copper, natural graphite, lithium, natural mica, and nickel. The EMRT is largely driven by battery supply chain due diligence requirements tied to regulations like the EU Battery Regulation.
Finally, there’s the AMRT. Launched in late 2022, the Additional Minerals Reporting Template is the newest and most flexible of the three, and it exists to capture due diligence data on minerals that don't fit neatly into CMRT or EMRT. Instead of a fixed mineral list, AMRT lets the requesting company specify up to ten minerals it wants a supplier to report on. These might include rare earth elements (REEs), aluminum, manganese, or whatever else a particular buyer has flagged as a priority.
The Responsible Minerals Initiative (RMI) released the current version, AMRT 1.31, alongside updated CMRT and EMRT versions, on April 17, 2026.
Why the Reporting Templates Are Confusing
Though the three mineral reporting templates might seem like variations on a single regulatory obligation, that assumption is incorrect. The CMRT has a clear legal anchor: it exists specifically to help companies comply with the conflict minerals requirements imposed by the Dodd-Frank Act and the EU Conflict Minerals Regulation. If a customer sends you a CMRT request, you are effectively under a legal obligation to fill it out and report on your mineral sourcing.
AMRT, on the other hand, is nothing like that. No existing regulation names AMRT as a compliance mechanism. Further, completing one isn't a legal obligation the way filing a Form SD is for SEC-covered companies reporting on 3TG.
And yet EMRT and AMRT requests from original equipment manufacturers (OEMs) sourcing from direct and sub-tier suppliers have surged over the past eighteen months, particularly in industries like automotive, electronics, and aerospace. So even though there haven’t been any significant regulatory changes, plenty of suppliers are currently navigating new due diligence obligations. But here’s the rub: for a supplier trying to continue doing business with a major OEM, the difference between "legally required" and "contractually required” has never been less meaningful. If a large OEM customer wants supply chain due diligence for five different rare earth elements, their supplier will likely feel compelled to comply.
This trend is arguably part of a larger pattern in conflict minerals reporting over the past several years. While no regulatory changes have actually made it over the finish line—several underlying legal questions have kept potential expansions in limbo—conflict minerals reporting is still evolving. That’s because OEMs are living in a new compliance reality, one where customer expectations, investor pressure, and the broader ascendance of ESG and responsible sourcing have a stronger influence than ever. Those influences are being passed on to suppliers, who must now carry out the due diligence work demanded by this new supply chain environment.
Why the Critical Mineral Scope Keeps Growing
There's a strong argument to be made that the expanding footprint of the AMRT isn't a temporary trend. Governments across the U.S., the EU, and the Asia-Pacific region are increasingly designating specific minerals as critical to national security and economic resilience. Every time a new mineral gets flagged as strategically important—whether it’s an REE tied to defense manufacturing or a mineral essential to battery production—there's a reasonable chance it ends up as a candidate for AMRT reporting. And this cause-and-effect is happening much faster than existing regulations typically expand or new laws are legally implemented.
For manufacturers in aerospace and defense, semiconductor manufacturing, and energy infrastructure, this new trend matters more than it does for companies that preside over smaller, more one-dimensional supply chains. Chipmakers and aircraft manufacturers rely on minerals that extend well beyond the traditional conflict minerals list. If your BOM includes rare earth magnets, special alloys, or emerging battery chemistries, there's a decent chance a customer is going to ask you to document where those materials come from. Increasingly, an AMRT is the primary vehicle for these types of requests.
What the AMRT Means for Existing Compliance Programs
Compliance teams that built their conflict minerals reporting process entirely around CMRT may have to take a long, hard look at whether that longstanding model is going to suffice in this new environment. However, there are several modest steps organizations can take to strengthen their compliance posture:
Businesses should always distinguish between their legal obligations and customer obligations, and track them differently. CMRT compliance tied to Dodd-Frank Section 1502 of the EU Conflict Minerals Regulation should trigger a workflow distinct from responding to a customer's EMRT or AMRT request. Treating them as interchangeable can create confusion about what's actually mandatory versus what's a relationship requirement. Over time, that confusion can make it harder to prioritize due diligence obligations when resources are tight.
Companies should not assume AMRT completion is optional just because it's not legally required. If a strategic customer is asking for it, declining or delaying can affect that relationship in ways that have nothing to do with regulatory risk, but could ultimately prove just as disastrous. Teams should treat AMRT requests from the right customers with the same seriousness they historically give to CMRTs.
Suppliers also need to be keeping an eye on the different versions of all three templates that the RMI has been publishing in recent years. The initiative updates CMRT, EMRT, and AMRT on a regular cycle; mismatches between a supplier’s template and what a customer expects create confusion and friction that eats up a compliance team’s time and bandwidth. The April 2026 updates were relatively minor from a scope perspective, but that won't always be the case. A supplier caught using an outdated template can face the same credibility questions as one who never responded at all.
Finally, manufacturers may want to build in the ability to track and respond to mineral scope changes over time, rather than just new template version numbers. Because AMRT's mineral list isn't fixed the way the CMRT is, a customer's AMRT request could change over time. Programs that treat the scope of minerals they are responsible for tracking as something to be actively monitored are more likely to give themselves the time and breathing room to respond effectively when that scope changes.
The Moving Target of Conflict Minerals Reporting
The broader practice of responsible minerals due diligence is expanding, even if the actual legal regulations have not changed meaningfully over the past year or two. These changes are driven by a combination of OEM priorities, market expectations, and the growing geopolitical significance of many minerals. Those suppliers that are willing to accept these new conditions and start developing a stronger grasp of their raw material sourcing will be better-positioned to handle the demands two, five, or even 10 years from now.
Compliance platform Z2 was built for exactly this kind of regulatory volatility. The tool helps businesses trace both 3TG metals and other critical minerals back to their original smelter, giving teams the flexibility to respond to both regulatory requirements and customer demands. In addition, Z2 generates CMRTs, EMRTs, and AMRTs within the software, reducing user legwork and creating a more seamless compliance workflow.
To learn more about Z2 and its flexible mineral reporting capabilities, schedule a free trial with one of our product experts.
