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Article Highlights:
- The Responsible Minerals Initiative created the conflict mineral reporting template, or the CMRT, as a way for businesses to convey information about the origins of their natural resources to other supply chain stakeholders. The CMRT allows companies to disclose information related to the country of origin (COO) of their minerals, the smelters or refiners they sourced it from, and other supply chain data.
- The CMRT is typically updated once a year and has gone through a number of different versions since its inception in 2013. The latest version of the reporting document, CMRT 6.6, was released to the public on April 17, 2026.
- The latest version of the CMRT includes a number of changes that aim to streamline the process of disclosing information on mineral sourcing and reduce the potential of conveying outdated or inaccurate information down the supply chain.
While minerals now play a major role in global manufacturing, sourcing materials like tin, tungsten, and cobalt has proven to be a risky endeavor in recent years. Many of the world's most important minerals are extracted from mines in conflict zones and other dangerous geographical locations, and the profits from these operations often go toward funding businesses engaged in forced labor, exploitation, and other human rights abuses.
The Responsible Minerals Initiative (RMI) was formed to combat this supply chain challenge. Since it was founded in 2008, the RMI has worked to enforce responsible mineral sourcing across the globe, imposing obligations on businesses to demonstrate that the raw materials they incorporate into their products were not extracted from dangerous or exploitative smelters and refiners. As the RMI explains, the industry association serves "as a bridge between upstream and downstream companies, facilitating accountability and transparency through third-party assessments, facility data, and reporting on minerals due diligence."
The RMI typically releases a new conflict mineral reporting template (CMRT) once a year, evolving the framework it provides and the information it asks companies to collect on behalf of their supply chain partners. With the RMI releasing CMRT 6.6 in April, it's a good time to take a closer look at the document and see how the obligations on in-scope businesses have changed in 2026.
What Are Conflict Minerals?
Conflict minerals are natural resources that are mined or smelted in regions engaged in armed conflict, controlled by dangerous militias and other paramilitary groups, or involving labor exploitation and human rights abuses. While this is the broad definition of a conflict mineral, today the term largely refers to a specific set of minerals associated with high-risk regions: tin, tantalum, tungsten, and gold. These are often abbreviated as "3TG."
Organizations that source any of the 3TG minerals should be aware of one key nuance: The U.S. Securities and Exchange Commission (SEC), which regulates conflict mineral disclosures in the U.S., defines conflict minerals as any of the 3TG metals, regardless of where they were actually sourced from. "For example, tin extracted in Canada, Russia or Argentina is considered a conflict mineral by definition," according to the RMI.
What Is the CMRT, and What Are Its Obligations?
The Responsible Minerals Initiative created the conflict mineral reporting template, or the CMRT, as a way for businesses to convey information about the origins of their natural resources to other supply chain stakeholders. The CMRT allows companies to disclose information related to the country of origin (COO) of their minerals, the smelters or refiners they sourced it from, and other supply chain data.
In general, the CMRT requires organizations to disclose the specific smelter or refiner (SOR) from which they sourced any of the 3TG minerals, as well as the COO.
When Was CMRT 6.6 Introduced?
The CMRT is typically updated once a year and has gone through a number of different versions since its inception in 2013. The latest version of the reporting document, CMRT 6.6, was released to the public on April 17, 2026.
What's Different About CMRT 6.6?
The latest version of the CMRT includes a number of changes that aim to streamline the process of disclosing information on mineral sourcing and reduce the potential of conveying outdated or inaccurate information down the supply chain.
Stronger Product Identifications
The newest version of the CMRT includes more comprehensive coverage for identifying products with connections to minerals and other natural resources. Version 6.6 features fields for "Requester Product Number" and "Requester Product Name." By expanding the fields in this way, downstream customers will have a more detailed understanding of the minerals in the products they're sourcing and the potential that those minerals are contaminating their supply chain.
Updated ISO Codes
CMRT 6.6 also includes new codes from the International Organization for Standardization (ISO) tied to country, state, and province. This update mainly serves to facilitate greater consistency across compliance documentation and strengthen risk management.
Compatibility With IPC-1755
The Responsible Mineral Initiative has updated the reporting document to align with IPC-1755, a mineral reporting framework maintained by the Global Electronics Association (previously known as the Institute for Printed Circuits, or IPC).
Updated Smelters
Finally, the CMRT includes new smelters and refiners that have been identified over the past year. Access to the updated SOR list in the CMRT will help organizations strengthen their visibility, transparency, and data accuracy, providing all supply chain stakeholders with better intelligence to inform due diligence and risk management measures.
The Key Benefits of CMRT 6.6
Unlike many new developments in the regulatory space, the new Conflict Mineral Reporting Template is not something that businesses need to be approaching with fear or trepidation. On the contrary, it should actually be seen as beneficial to organizations operating within global supply chains and sourcing critical minerals from all over the world. CMRT 6.6's updated list of smelters and refiners will help suppliers and original equipment manufacturers (OEMs) maintain better data while also promoting stronger transparency throughout supply chains.
In addition, the document's improved product identifications will provide greater clarity in CMRT declarations. This can help customers and other supply chain stakeholders better understand their specific critical mineral dependencies, where those natural resources are being sourced from, and what products carry them. This type of enhanced supply chain visibility confers value that goes beyond compliance, giving businesses the insights they need to manage sourcing risks and strengthen supplier diversification.
Finally, the improved IPC compatibility means that companies will have an easier time applying their CMRT declarations to other ESG and material compliance frameworks that draw from IPC standards. Over time, this higher level of synchronization will reduce the regulatory burden on businesses, relieving them of some of the drudgery of trying to determine which aspects of their CMRT can be applied to IPC-1755 standards and which cannot.
How Businesses Can Comply With CMRT 6.6
Despite the introduction of this new reporting template, the reality is that the overall compliance obligations imposed by the Responsible Minerals Initiative (RMI) have not changed in a significant way. One aspect of the new reporting template businesses should pay close attention to, however, is the new smelter list. Companies that want to stay on top of their supply chains should cross-reference the new list against their own supply chain to see if any of the statuses of their own suppliers have changed.
This is a critical step, as OEMs could be sourcing from a smelter or refiner deep in their subtier that the RMI only recently tied to conflict minerals. Businesses that want to stay compliant and avoid a reputational crisis need to act quickly and decisively to extricate those suppliers from their networks. First, however, they need access to the critical mineral reporting and documentation that identifies those entities.
Tracing Critical Minerals to Their Source
For many businesses, the due diligence required to collect mineral reporting documents from their suppliers can take up a disproportionate amount of their team's bandwidth. But given the regulatory stakes involved, that hardly means that companies can afford to neglect these compliance responsibilities. OEMs that source critical minerals and find themselves in this difficult position can benefit from the data visibility and supply chain expertise of a compliance tool.
Compliance software tool Z2 provides companies with a robust foundation for conflict minerals reporting. Z2 has a critical mineral reporting database with CMRTs, EMRTs, and AMRTs from thousands of suppliers all over the world, giving users a highly effective resource for fulfilling all their conflict minerals reporting obligations. In addition, Z2 complements its out-of-the-box coverage with comprehensive due diligence services: experienced teams can reach out to suppliers to obtain all necessary minerals reporting templates, helping users stay compliant—even when their supply chains change or smelter statuses evolve.
Finally, Z2 teams carrying out supplier campaigns are able to flag manufacturers connected to high-risk smelters operating in conflict zones, utilizing forced labor, or embroiled in human rights abuses. This risk visibility allows organizations to identify the tier 1 and tier 2 suppliers sourcing conflict minerals and either work with them to make changes or remove them from the supply chain.
To learn about how Z2 helps businesses adhere to conflict mineral regulations and identify compliance risks in their supply chains, schedule a free trial with one of our product experts.
