What does Dodd-Frank Section 1502 require, and who is subject to it?

Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 amended the US Securities Exchange Act of 1934 to require SEC-registered issuers whose products contain tin, tantalum, tungsten or gold (the 3TG metals) necessary to the functionality or production of a product they manufacture or contract to manufacture, to file an annual Form SD with the SEC. When the 3TG originates from the Democratic Republic of the Congo (DRC) or an adjoining country, the issuer must also file a Conflict Minerals Report (CMR) describing its supply-chain due diligence carried out in conformity with a nationally or internationally recognised framework, in practice the OECD Due Diligence Guidance. Private companies and non-issuers are not directly subject, but typically receive cascading requests from their issuer customers.

Does the 2017 SEC enforcement stay end the obligation?

No. In April 2017 the SEC issued a statement indicating that it would not recommend enforcement action against an issuer that filed Form SD without making the "DRC conflict-free" / "not been found to be DRC conflict-free" / "DRC conflict-undeterminable" determination on its products. The disclosure obligation itself (Form SD filing, description of due diligence, supplier inquiry) remains in force and is enforced. The stay narrows the binary product determination, not the overall disclosure regime. Most filers continue to use the CMRT to roll up supplier data and the RMAP smelter list to characterise their smelter coverage.

How does EU Regulation 2017/821 differ from Dodd-Frank?

Regulation (EU) 2017/821 entered into application on 1 January 2021. It targets EU importers (upstream operators) of 3TG ores and metals above annual volume thresholds set out in Annex I, who must perform OECD-aligned due diligence and submit to independent third-party audit. The obligated parties are upstream importers, not downstream OEMs, which is a structural difference from Dodd-Frank (which targets SEC-registered issuers whatever their position in the chain). The geographic scope is broader than the DRC and adjoining countries: the regulation covers all conflict-affected and high-risk areas (CAHRA) globally, on the basis of an indicative non-exhaustive list published by the European Commission.

What are the CMRT and EMRT templates?

The Conflict Minerals Reporting Template (CMRT) is an Excel template maintained by the Responsible Minerals Initiative (RMI, formerly RBA + GeSI Conflict-Free Sourcing Initiative). It standardises the collection of smelter-level data on tin, tantalum, tungsten and gold from suppliers, and is the de facto market standard for cascaded 3TG declarations. The current revision is CMRT 6.40 (2024). The Extended Minerals Reporting Template (EMRT) is the analogous template for cobalt and mica, with the same data architecture (smelter identification, country of origin, status under RMI assurance). EMRT 1.x (2024) is the current revision. Both templates rest on the RMI public list of smelter and refiner facilities for cross-checks.

What is the OECD five-step framework?

The OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (3rd edition 2016, with sectoral supplements and updates through 2024) defines a five-step framework adopted by Dodd-Frank, EU 2017/821 and most national regimes. Step 1: establish strong company management systems (policy, internal team, supplier engagement, grievance mechanism). Step 2: identify and assess risks in the supply chain. Step 3: design and implement a strategy to respond to identified risks. Step 4: carry out independent third-party audit of supply-chain due diligence at identified points in the supply chain. Step 5: report annually on supply-chain due diligence. The framework is mineral-agnostic and is applied to 3TG, cobalt and mica.

What is RMAP and how is the "conformant smelter" list used?

RMAP, the Responsible Minerals Assurance Process, is the audit programme operated by the RMI. Independent third-party auditors assess smelters and refiners against the RMI Standards (3TG Standard, Cobalt Refiner Standard, Mica Processor Standard), which transpose the OECD Due Diligence Guidance into smelter-level requirements. Audited facilities are classified as Conformant, Active (audit in progress), or Non-Conformant, and the public list is updated continuously on the RMI website. Downstream electronics companies typically use this list as the practical proxy for "responsibly sourced": a CMRT in which all reported smelters appear as Conformant on the RMAP list is regarded as the cleanest possible position, and any non-conformant smelter triggers an escalation or substitution process.

Do cobalt and mica fall under Dodd-Frank or EU 2017/821?

No, neither regulation covers cobalt or mica directly. Dodd-Frank Section 1502 is restricted to the four 3TG metals, and EU 2017/821 lists only tin, tantalum, tungsten and gold in its scope. Cobalt and mica are covered by separate due diligence expectations driven by customer requirements, by the German Supply Chain Due Diligence Act (LkSG, 2021), by the EU Forced Labour Regulation (2024) which prohibits products of forced labour from the EU market, by the EU Battery Regulation 2023/1542 (Article 49 due diligence on cobalt, natural graphite, lithium and nickel from 18 August 2025), and by voluntary frameworks transposed via the EMRT and the Cobalt Refiner Standard. The trajectory aligns the two minerals with the 3TG framework in operational practice, ahead of an explicit regulatory consolidation.

What is the most common pitfall in supplier CMRT collection?

The single most frequent pitfall is treating supplier responses literally without cross-checking against the RMAP smelter list. A supplier reply of "DRC conflict-free" with no named smelters, or with smelters that are not on the RMI public list, is unverifiable and offers no due-diligence value. A CMRT must be evaluated on three axes: response coverage (number of suppliers that returned a populated CMRT versus the BOM total), smelter identification (each metal must list the smelter / refiner names and identifiers, not generic statements), and RMAP status of those smelters (Conformant, Active, or Non-Conformant). A CMRT older than twelve months is also generally treated as stale by downstream customers and triggers a re-issue request.

Conflict minerals: Dodd-Frank, EU 2017/821, CMRT and EMRT

Author Hugues Orgitello Last updated 27 May 2026 ~17 min read

Guide - Conflict minerals due diligence

Conflict-mineral due diligence is one of the older but most operationally demanding supply-chain compliance regimes for electronics. The pivot statute, Section 1502 of the Dodd-Frank Act of 2010, imposes annual disclosure obligations on SEC-registered issuers whose products contain tin, tantalum, tungsten or gold (3TG) from the DRC or adjoining countries. Regulation (EU) 2017/821, applicable since January 2021, extends a parallel due-diligence obligation to EU importers of 3TG ores and metals across all conflict-affected and high-risk areas (CAHRA), with OECD-aligned third-party audit. The operational backbone in both regimes is the CMRT (3TG) and its sibling EMRT (cobalt, mica) templates maintained by the Responsible Minerals Initiative, cross-checked against the RMAP conformant smelter list. This guide maps the regulatory framework, the template mechanics, the OECD five-step process, and the recurring pitfalls in supplier data rollups for electronics manufacturers.

Dodd-Frank Section 1502: scope and current state

The Dodd-Frank Wall Street Reform and Consumer Protection Act was enacted in 2010 in the wake of the 2008 financial crisis. Section 1502 of that act addresses a separate concern: the financing of armed groups in the eastern Democratic Republic of the Congo through the trade of certain minerals. It amended the Securities Exchange Act of 1934 by inserting a new Section 13(p), implemented by SEC Rule 13p-1 and the associated Form SD.

Obligated parties

The rule applies to SEC-registered issuers (companies that file periodic reports with the SEC) for which the four metals tin, tantalum, tungsten or gold are necessary to the functionality or production of a product they manufacture or contract to manufacture. The "necessary" test is interpreted broadly: a 3TG metal that appears in solder joints, capacitor anodes, plating, wire bonds or contacts of a product the issuer markets is in scope, even if the issuer does not directly procure the raw metal.

The rule explicitly does not apply to private companies, non-issuers, retailers, or to issuers that only resell unmodified products. In practice, however, downstream issuers cascade their reporting requirement to their entire supplier base through contractual clauses, with the result that a large share of the global electronics supply chain is functionally subject to Dodd-Frank reporting even when not legally bound to the SEC.

Form SD and the Conflict Minerals Report

A subject issuer must file Form SD annually with the SEC. The form has two key questions:

Whether the issuer's products contained 3TG necessary to functionality or production.
If so, the country of origin of the 3TG, and whether any of it originated in the DRC or one of the nine adjoining countries (Angola, Burundi, Central African Republic, Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, Zambia).

If the issuer's reasonable country-of-origin inquiry (RCOI) does not exclude DRC-region origin, the issuer must additionally file a Conflict Minerals Report (CMR) as an exhibit to Form SD. The CMR describes the issuer's supply-chain due diligence carried out under a recognised framework, in practice the OECD Due Diligence Guidance.

The 2017 SEC enforcement stay

In April 2017, the SEC's Division of Corporation Finance issued a statement that it would not recommend enforcement action against issuers that filed Form SD without making the "DRC conflict-free" / "has not been found to be DRC conflict-free" / "DRC conflict-undeterminable" determination historically required by the rule. The statement followed a federal court decision (NAM v. SEC) finding the compelled product-level label inconsistent with the First Amendment.

The narrow but operationally important consequence: the disclosure obligation persists (RCOI, due diligence description, CMR filing) but the binary product-level label is paused. Most issuers therefore continue to file Form SD and a CMR, build supplier data through the CMRT, and characterise their smelter coverage through the RMAP conformant list, without formally declaring their products "DRC conflict-free" or otherwise.

EU Regulation 2017/821: the European angle

Regulation (EU) 2017/821 of the European Parliament and of the Council was adopted on 17 May 2017 and entered into application on 1 January 2021 after a transition period. It is the EU analogue of Dodd-Frank, with three structural differences worth understanding.

Obligated parties: upstream importers

EU 2017/821 imposes due-diligence obligations on Union importers of 3TG ores and metals, that is, upstream operators bringing tin, tantalum, tungsten or gold (whether in ore, concentrate, or smelted form) into the EU customs territory. Downstream operators (component manufacturers, EMS, OEMs) are not directly bound, although the regulation encourages downstream due diligence and the European Commission maintains an indicative list of recognised supply-chain due diligence schemes.

This is a fundamental structural difference from Dodd-Frank, which targets downstream issuers with SEC reporting obligations. The two regimes are complementary: Dodd-Frank captures information at the issuer level on the entirety of the chain, while EU 2017/821 captures information at the import-into-EU level for the upstream segment.

Volume thresholds

EU 2017/821 imposes obligations only above annual volume thresholds set out in Annex I of the regulation, defined per Combined Nomenclature (CN) code. Below the thresholds, the importer is exempt. The thresholds are high enough that small specialised importers are excluded, while preserving capture of the major upstream flows.

Geographic scope: CAHRA globally

The geographic scope is all conflict-affected and high-risk areas (CAHRA) globally, not just the DRC and adjoining countries. The European Commission publishes a non-exhaustive indicative list of CAHRA (most recent revisions through 2024) on the basis of armed-conflict, governance and human-rights indicators. The list is informative and not binding: an importer must perform its own risk assessment against the OECD Guidance criteria.

This broader geography captures sources outside Africa (parts of Latin America, Central Asia, the Middle East) that Dodd-Frank only addressed by analogy through cascaded supplier inquiries.

Audit requirement

Importers above the thresholds must submit their supply-chain due diligence to independent third-party audit consistent with the OECD framework. The Commission maintains, under Article 8 of the regulation, a list of recognised supply-chain due diligence schemes (LBMA, RMAP, RJC and similar) whose adherent importers are presumed compliant with the audit step. This recognition mechanism is the practical efficiency lever for upstream operators already covered by an industry programme.

OECD Due Diligence Guidance: the five-step framework

Both Dodd-Frank and EU 2017/821 reference the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, published in a 3rd edition in 2016 and supplemented through 2024 with sectoral guidance (Gold, Tin/Tantalum/Tungsten) and mineral-specific updates. The Guidance defines a five-step framework that any conformant due-diligence programme must implement.

Step 1: strong management systems

The company adopts a supply-chain policy for the minerals in question, communicates it internally and to suppliers, sets up an internal team accountable for due diligence, establishes a chain-of-custody or traceability system that tracks the minerals from smelter / refiner upward, and implements a grievance mechanism allowing third parties to raise concerns.

Step 2: identify and assess risks

The company maps its supply chain, identifies the smelters and refiners of the relevant metals, gathers information on those facilities (location, ownership, sourcing practices, audit status under RMAP or equivalent), and assesses the risk of contributing to conflict or serious human-rights harm under the OECD Annex II red flags.

Step 3: design and implement a response

For each identified risk, the company defines a mitigation strategy: continued engagement with risk mitigation, temporary suspension, or termination of the relationship. The OECD Guidance explicitly recognises that outright disengagement is rarely the appropriate first response, and prefers engagement with risk mitigation to support responsible sourcing in conflict-affected areas.

Step 4: independent third-party audit

Smelters and refiners must be subject to independent third-party audit of their due diligence practices at identified points in the supply chain. This is the step where the RMAP programme (and equivalent LBMA, RJC processes) plays its central role: RMAP audits substitute, in practice, for company-by-company audit programmes that would be operationally impractical.

Step 5: annual report on due diligence

The company reports publicly, at least annually, on its supply-chain due diligence. For Dodd-Frank issuers this report takes the form of the CMR filed with Form SD. For EU importers the report is part of the Article 7 disclosure obligation. For downstream operators not directly bound, the report typically takes the form of a published Conflict Minerals Policy and annual progress statement.

CMRT and EMRT: the operational templates

The Responsible Minerals Initiative (RMI), hosted by the Responsible Business Alliance (RBA), maintains the industry-standard reporting templates. The RMI is the successor to the joint RBA + GeSI Conflict-Free Sourcing Initiative (CFSI), rebranded in 2017.

CMRT for 3TG

The Conflict Minerals Reporting Template (CMRT) is an Excel workbook with a fixed structure: declaration scope (product level or company level), 3TG metals per sheet, smelter and refiner identification per metal, source country, RMAP audit status reference, and supporting documents. The current revision is CMRT 6.40 (2024), which introduced changes in validation rules and several field definitions; rollups from older CMRTs (5.x, 6.0x) require a mapping pass.

The CMRT is the operational mechanism through which a downstream user collects supplier declarations, aggregates the smelter list at BOM or product level, and cross-checks against the RMAP conformant list. It is not a regulatory submission in itself, but is the structured data input that feeds Form SD CMRs, EU 2017/821 import declarations, and customer compliance requests.

EMRT for cobalt and mica

The Extended Minerals Reporting Template (EMRT), current revision 1.x (2024), is the analogous template for cobalt and mica, two minerals that face significant due-diligence concerns (artisanal cobalt mining in the Katanga belt, child labour in Indian mica). EMRT shares the architectural model of CMRT but is built around the Cobalt Refiner Standard and the Mica Processor Standard of the RMI, rather than the 3TG Standard.

Battery-equipped products (cellular phones, IoT devices, electric vehicles, energy storage systems) systematically require a cobalt EMRT alongside the 3TG CMRT. Mica-containing products (insulation in heaters and motors, electronic substrates) require a mica EMRT. The two templates are managed in parallel, often by the same compliance team.

RMI smelter and refiner list

The RMI maintains the public smelter and refiner list which is the foundation of both templates. The list assigns a unique identifier (CID, Compliance ID) to each known facility, records its location and ownership, and indicates its RMAP audit status: Conformant, Active, or no Active engagement. The Conformant list is the operational proxy used downstream to characterise a smelter as "responsibly sourced".

RMAP: the assurance backbone

The Responsible Minerals Assurance Process (RMAP) is the audit programme operated by the RMI. Independent third-party auditors assess smelter and refiner facilities against the relevant RMI Standard: the 3TG Standard, the Cobalt Refiner Standard, or the Mica Processor Standard, each of which transposes the OECD Due Diligence Guidance into smelter-level audit criteria.

The audit cycle typically runs on a three-year horizon, with annual surveillance. A facility classified Conformant is recognised as having implemented OECD-aligned due diligence; classification as Active indicates an audit in progress; absence from both lists indicates a facility outside the RMI assurance programme.

For downstream electronics companies, the public RMAP Conformant smelter list is the operational baseline used to evaluate supplier CMRTs and EMRTs. A reported smelter that is Conformant on RMAP is considered the cleanest position achievable; a reported smelter that is Active is provisionally accepted; a reported smelter that is neither Conformant nor Active triggers an escalation, supplier engagement, or substitution process. No regulatory regime mandates that products only contain Conformant-smelter metal, but the smelter list is the de facto industry standard for characterising effort.

Other instruments in the conflict-minerals landscape

Beyond Dodd-Frank, EU 2017/821 and the OECD Guidance, several adjacent instruments form the broader landscape.

LBMA Responsible Gold Guidance

The London Bullion Market Association (LBMA) publishes the Responsible Gold Guidance, which applies to gold refiners on the LBMA Good Delivery List and is one of the OECD-aligned schemes recognised under EU 2017/821. LBMA-Good-Delivery refiners are typically the gold smelters of choice for downstream CMRT rollups in jewellery, electronics and automotive sectors.

ITSCI

The International Tin Supply Chain Initiative (ITSCI), operated by the International Tin Association, is a traceability programme focused on tin, tantalum and tungsten at the upstream segment in the Great Lakes region (DRC, Rwanda, Burundi, Uganda). It bag-and-tag tracks minerals from mine to smelter and is one of the oldest operational due-diligence programmes in the conflict-minerals space.

China RMI

A collaboration between the China Chamber of Commerce of Metals, Minerals & Chemicals Importers and Exporters (CCCMC) and the RBA / RMI provides a Chinese-language and Chinese-context variant of the responsible-minerals programme, helping Chinese smelters and downstream operators align with OECD Guidance and RMAP requirements.

UK Modern Slavery Act and EU Forced Labour Regulation

The UK Modern Slavery Act 2015 requires UK commercial organisations above an annual turnover threshold to publish an annual statement on the steps taken to ensure that slavery and human trafficking are absent from their operations and supply chains. The EU Forced Labour Regulation (2024) prohibits placing on the Union market products made with forced labour, with enforcement mechanisms phasing in. Both instruments overlap with conflict-minerals due diligence without being limited to 3TG or to specific minerals, and a robust CMRT / EMRT process is one of the building blocks of compliance.

EU Battery Regulation Article 49

Regulation (EU) 2023/1542 (the EU Battery Regulation) imposes, from 18 August 2025, a battery-specific supply-chain due-diligence obligation on cobalt, natural graphite, lithium and nickel, structured along the OECD five-step framework. For battery manufacturers and battery integrators, the Article 49 obligation extends and reshapes the cobalt EMRT process into a regulatory rather than purely voluntary regime. See the EU Battery Regulation 2023/1542 guide and the IEC 62133 and UN 38.3 battery safety guide for the wider battery regulatory frame.

Practical workflow for an EMS / OEM

The operational workflow that an electronics EMS or OEM typically runs on an annual cycle:

Publish a Conflict Minerals Policy statement aligned with OECD Annex II, committing to OECD-aligned due diligence and to engagement-with-mitigation over disengagement.
Issue CMRT and EMRT requests to all direct suppliers of components containing 3TG, cobalt or mica, with a defined response deadline (typically 30 to 60 days).
Collect and validate supplier CMRTs / EMRTs: parse Excel files, normalise smelter identifiers to RMI CIDs, flag unidentified smelters, flag responses with template versions older than the current revision.
Roll up to BOM and product level: aggregate the smelter list per product, using the BOM and component-level CMRT mapping.
Cross-check against the RMAP Conformant list: for each reported smelter, look up its current RMAP status on the RMI public list, classify Conformant / Active / Non-Conformant, and compute the share of metal volume covered by each status.
Escalate non-conformant smelters: open a supplier dialogue, request substitution, or accept with documented mitigation if substitution is not feasible.
Report internally and externally: produce internal due-diligence dashboards, supply CMR exhibits to issuer customers under Dodd-Frank cascade, file Form SD and CMR if directly an SEC issuer, publish an annual due-diligence statement.
Refresh annually: CMRTs older than twelve months are systematically treated as stale; a new annual cycle re-issues requests.

For an electronics design house supporting OEM clients, the workflow is typically delivered as a service: BOM analysis, supplier CMRT chase, smelter rollup, RMAP cross-check, and report drafting.

Comparison: Dodd-Frank vs EU 2017/821

Criterion	Dodd-Frank Section 1502	EU Regulation 2017/821
Pivot statute	Dodd-Frank Wall Street Reform Act of 2010, SEC Rule 13p-1	Regulation (EU) 2017/821
Application date	Reporting cycles since 2014	Applicable from 1 January 2021
Obligated party	SEC-registered issuers manufacturing or contracting to manufacture products with 3TG	EU importers of 3TG ores and metals above Annex I thresholds
Position in chain	Downstream	Upstream
Minerals in scope	3TG (tin, tantalum, tungsten, gold)	3TG (tin, tantalum, tungsten, gold)
Geographic scope	DRC and nine adjoining countries	All CAHRA globally
Volume thresholds	None	Annex I per CN code
Annual filing	Form SD + CMR with SEC	Annual due-diligence report, audit summary to EU MS
Independent audit	Optional (depends on RCOI conclusion)	Mandatory above thresholds
Recognised due diligence framework	OECD Guidance	OECD Guidance
Operational template	CMRT (de facto)	CMRT (de facto)
Smelter list backbone	RMAP Conformant list (de facto)	RMAP and equivalent recognised schemes

The two regimes are complementary, not duplicative. A global electronics group typically maintains a single combined programme that satisfies both, with the CMRT and RMAP list as the common operational backbone.

Common pitfalls

A short list of recurring errors in supplier CMRT / EMRT collection and rollup.

Accepting "DRC conflict-free" responses without named smelters. A supplier statement that the product is "conflict-free" with no listed smelter is unverifiable and offers zero due-diligence value. The CMRT must name smelters per metal.
Stale CMRT older than twelve months. A CMRT older than one year is generally treated as stale and triggers re-issue. Downstream customers will reject a stale CMRT in audit.
CMRT 6.x rollup errors from older templates. CMRT 6.40 introduced changes in validation and field definitions; mechanical concatenation of supplier files of different revisions produces broken rollups. A mapping pass to the current revision is required.
Missing cobalt EMRT for battery-equipped products. A product containing a Li-ion cell requires an EMRT covering cobalt, not just a CMRT for 3TG. Battery-equipped products without an EMRT are operationally non-compliant under most customer due-diligence programmes.
Confusing EU 2017/821 with Dodd-Frank. The two regimes target different operators (upstream importers vs SEC issuers) at different segments of the chain. A downstream OEM is not directly subject to EU 2017/821 but is typically subject to a Dodd-Frank cascade.
Skipping OECD Step 4 (independent audit). Some programmes describe extensive supplier engagement (Steps 1, 2, 3) but never reference any independent third-party audit at smelter level, which is the role of the RMAP / LBMA / equivalent schemes. A due-diligence narrative without that audit step is incomplete.
Marketing "conflict-free" labels without basis. The 2017 SEC stay paused the binary product label; the FTC retains jurisdiction over misleading environmental and ethical marketing claims. A "conflict-free" claim on packaging without documented OECD-aligned due diligence and RMAP backing exposes the company to FTC enforcement risk.
Treating CAHRA as identical to DRC + adjoining countries. Under EU 2017/821 the geographic scope is all CAHRA globally, not the Great Lakes region alone. A risk assessment limited to Africa misses CAHRA sources elsewhere.
Confusing the Conformant list with a legal requirement. No regulatory regime requires Conformant-only smelter sourcing. RMAP Conformant is a de facto industry standard, not a legal mandate. Failing a Conformant-only test is not in itself a regulatory violation, but is a commercial weak point in CMRT rollups to customers.

Cross-reference: adjacent compliance

For a connected electronic product placed on the EU and US markets simultaneously, the conflict-minerals programme integrates with several adjacent regimes:

EU Battery Regulation 2023/1542: Article 49 due diligence on battery raw materials from August 2025. See the EU Battery Regulation guide.
IEC 62133 and UN 38.3 for battery safety and transport: physical and chemical product safety for the battery itself. See the battery safety and transport guide.
RoHS 2011/65/EU: hazardous substances in the finished EEE, separate from the upstream mineral sourcing question. See the RoHS guide.
REACH SVHC: chemical substances of very high concern, with declaration obligations under Article 33. See the REACH SVHC guide.

The conflict-minerals programme sits at the upstream raw-material level of the supply chain, while RoHS and REACH operate at the finished-product chemical-composition level. Both layers must be addressed in a coherent compliance file.

Key takeaways

Dodd-Frank Section 1502 (2010) imposes annual Form SD + CMR filing on SEC-registered issuers whose products contain 3TG necessary to functionality or production, with possible DRC-region origin.
The 2017 SEC enforcement stay paused the binary "DRC conflict-free" product label but did not end the underlying disclosure regime.
Regulation (EU) 2017/821 (in force since January 2021) covers EU upstream importers of 3TG ores and metals above Annex I volume thresholds, across all CAHRA globally, with mandatory third-party audit.
The OECD Due Diligence Guidance (3rd ed 2016, updated through 2024) is the reference framework cited by both regimes, structured around five steps: management systems, risk identification, response, independent audit, annual report.
The CMRT 6.40 (2024) template covers 3TG; the EMRT 1.x (2024) template covers cobalt and mica. Both are maintained by the Responsible Minerals Initiative (RMI).
The RMAP Conformant smelter list is the de facto operational proxy for "responsibly sourced", although no regulation mandates Conformant-only sourcing.
Cobalt and mica are not in scope of Dodd-Frank or EU 2017/821, but are covered by EMRT, by the EU Battery Regulation Article 49 (from August 2025 for cobalt), and by overlapping forced-labour instruments.
A practical EMS / OEM workflow runs annually: policy publication, supplier CMRT / EMRT requests, BOM rollup, RMAP cross-check, escalation, internal and external reporting.
Pitfalls cluster around stale CMRTs, unnamed smelters, missing cobalt EMRT for battery products, CMRT revision mismatches, and unsupported "conflict-free" marketing claims.

For wider supply-chain and chemical-compliance context, see RoHS, REACH SVHC, EU Battery Regulation, IEC 62133 / UN 38.3 battery safety and transport, and the Glossary for definitions.

Sources & references

Dodd-Frank Wall Street Reform and Consumer Protection Act, Section 1502 , US Securities and Exchange Commission www.sec.gov/rules/final/2012/34-67716.pdf
Regulation (EU) 2017/821 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas , European Union eur-lex.europa.eu/eli/reg/2017/821/oj
OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, third edition , OECD www.oecd.org/corporate/mne/mining.htm
Responsible Minerals Initiative, CMRT and EMRT templates , Responsible Minerals Initiative www.responsiblemineralsinitiative.org/reporting-templates/
Responsible Minerals Assurance Process (RMAP) and conformant smelter list , Responsible Minerals Initiative www.responsiblemineralsinitiative.org/responsible-minerals-assurance-process/
LBMA Responsible Gold Guidance , London Bullion Market Association www.lbma.org.uk/responsible-sourcing
Regulation (EU) 2024/1781 on prohibiting products made with forced labour on the Union market , European Union eur-lex.europa.eu/eli/reg/2024/3015/oj