3TG

Materials & Environmental

Conflict Minerals Reporting (Dodd-Frank Section 1502) & EU Conflict Minerals Regulation

Your Products Contain 3TG. Can You Prove They're Not Funding Armed Conflict?

Conflict minerals compliance requires tracing tin, tantalum, tungsten, and gold (3TG) to their smelter of origin—across every tier of your supply chain. SEC disclosure deadlines are fixed. EU due diligence is mandatory. Your suppliers often don't know where their metals come from.

Certivo automates CMRT collection, validates smelter data against RMAP, and generates audit-ready reports in hours, not months.

Key Stats

• 4 Minerals requiring origin traceability (3TG)
• 300+ Conformant smelters and refiners on RMAP list
• 95% Supplier response rate with Certivo vs. 20-30% industry average

Regulation Overview

• Jurisdiction: United States (SEC) / European Union
• Regulatory Body: U.S. Securities and Exchange Commission (SEC); EU Member State authorities
• Regulation Number: Dodd-Frank Act Section 1502; EU Regulation 2017/821
• Effective Date: US: 2012 (reporting since 2014); EU: January 1, 2021
• Official Source: SEC Conflict Minerals / EU Regulation
• Key Threshold: US: "Necessary to functionality or production"; EU: Volume thresholds for importers

What are Conflict Minerals?

Conflict minerals are tin, tantalum, tungsten, and gold (3TG)—metals commonly used in electronics, automotive, aerospace, and industrial manufacturing. These minerals may originate from conflict-affected regions, including the Democratic Republic of Congo (DRC) and adjoining countries.

US Dodd-Frank Section 1502 requires SEC-reporting companies to conduct supply chain due diligence and file annual conflict minerals reports (Form SD) if 3TG are necessary to their products. The EU Conflict Minerals Regulation requires importers above volume thresholds to implement supply chain due diligence.

Key Components / Sub-Frameworks

SEC Form SD Filing Deadline: May 31 Annually

SEC-reporting companies must file Form SD conflict minerals reports by May 31 each year. Supplier CMRT collection typically requires 3-6 months. If you haven't started supplier outreach, your filing timeline is already at risk.

Key Compliance Requirements

Who Must Comply

• SEC-reporting companies whose products contain 3TG necessary to functionality or production
• EU importers of 3TG metals or ores above annual volume thresholds
• Companies in defense, aerospace, automotive, and electronics supply chains
• Any manufacturer responding to customer conflict minerals surveys
• Tier 1 suppliers flowing down OEM conflict minerals requirements
• Distributors and traders of 3TG metals subject to EU volume thresholds

Key Thresholds

"Necessary to functionality or production"

US: Triggers SEC reporting obligation

EU Volume Thresholds

• Tin: 100kg;
• Tantalum: 1kg;
• Tungsten: 100kg;
• Gold: 100kg annually

May 31

Annual SEC Form SD filing deadline

5 years

Record retention period for due diligence documentation

Core Obligations

1. Reasonable Country of Origin Inquiry (RCOI) — Determine if 3TG originated from covered countries
   DEADLINE: Before Form SD filing
2. Supply Chain Due Diligence — Conduct OECD-aligned due diligence if RCOI indicates DRC origin
   DEADLINE: Ongoing
3. Form SD Filing — File annual conflict minerals report with SEC
   DEADLINE: May 31 annually
4. CMRT Collection — Collect Conflict Minerals Reporting Templates from suppliers
   DEADLINE: Ongoing
5. Record Retention — Maintain due diligence records for 5 years
   DEADLINE: Ongoing

Conflict Minerals-Specific Pain Points

The CMRT Collection Nightmare

You send CMRT requests to 500 suppliers. 60% don't respond. 20% return incomplete templates. 10% submit CMRTs with "unknown" smelters throughout. Your team spends months chasing responses while the May 31 deadline approaches.

The Smelter Validation Gap

Your supplier's CMRT lists 15 smelters. Are they on the RMAP conformant list? Are the smelter IDs correct? Are any flagged as high-risk? Manual cross-referencing against the RMI database takes hours per supplier—and errors mean filing inaccurate reports.

The Multi-Tier Visibility Problem

You know your Tier 1 suppliers. But 3TG enters your supply chain at Tier 3, 4, or deeper. Your direct suppliers often don't know the smelter of origin for the metals in their components. Without supply chain traceability, your RCOI is incomplete.

The Annual Filing Scramble

Every year, the same panic: Form SD deadline approaching, supplier responses trickling in, CMRTs with missing data, no time to validate smelter information. Reactive compliance means your conflict minerals report becomes a best-effort estimate rather than defensible due diligence evidence.

Conflict Minerals Workflow

GET EVIDENCE IN

Collect CMRTs from Every Supplier—Without the Chasing
CORA launches automated CMRT campaigns, follows up in suppliers' native languages, and accepts responses in any format.

• Launch conflict minerals surveys to hundreds of suppliers with one click
• CORA-powered multilingual outreach with automated follow-up sequences
• Accept CMRTs in any version—RMI templates, custom formats, legacy versions
• Track response rates in real-time and escalate non-responders automatically

MAKE SENSE OF IT

Know Instantly Which Smelters Are RMAP Conformant
CORA-driven compliance intelligence extracts smelter data from CMRTs and validates against current RMI conformant smelter lists automatically.

• CORA parses CMRTs to extract smelter IDs, names, and countries
• Automatic validation against RMAP conformant smelter/refiner list
• Flags unknown, non-conformant, or high-risk smelters for review
• Identifies incomplete or inconsistent CMRT submissions

PROVE COMPLIANCE OUT

Respond to SEC Deadlines and Customer Requests in Hours, Not Weeks
Generate Form SD documentation and customer conflict minerals packages instantly from validated supplier data.

• One-click generation of Form SD supporting documentation
• Customer-specific conflict minerals response packages
• Complete smelter list with conformance status and country of origin
• Full audit trail documenting RCOI and due diligence steps

One Survey. 300+ Smelters Validated. SEC-Ready Evidence in Hours.

Certivo doesn't just collect CMRTs—it reads them, extracts smelter data automatically, and validates against the RMAP conformant list. When the May 31 deadline approaches, you're not scrambling—you have continuous visibility into your 3TG supply chain and audit-ready documentation on demand.

Features Tabs

Declaration Collection

Certivo's automated campaigns achieve 95% supplier response rates vs. 20-30% with manual outreach.

• Launch CMRT campaigns by supplier, product line, or business unit
• Multi-language outreach in suppliers' native languages
• Accept any CMRT version or format—no supplier reformatting required
• Intelligent follow-up sequences until suppliers respond

Smelter Extraction

Every smelter ID, name, and country extracted automatically from any CMRT format.

• CORA-enabled analysis parses CMRTs to extract smelter/refiner identification data
• Handles multiple CMRT versions and custom supplier templates
• Normalizes smelter names to RMI standard identifiers
• Flags data quality issues for human review

RMAP Monitoring

Always validated against current RMAP conformant smelter and refiner lists—not your last audit.

• Automatic sync with RMI conformant smelter database updates
• Flags non-conformant, unknown, or delisted smelters
• Country of origin validation for covered countries
• Risk scoring based on smelter conformance status

Due Diligence Documentation

Document your RCOI and due diligence process with complete audit trails.

• Structured workflow aligned to OECD five-step due diligence
• RCOI documentation with supplier response evidence
• Risk assessment records for flagged smelters
• Management sign-off tracking for due diligence steps

Customer Response

Generate Form SD documentation and customer conflict minerals responses in hours.

• One-click Form SD supporting documentation packages
• Customer-specific conflict minerals reports in any format
• Complete smelter list with conformance status
• Audit trail for regulatory defense and customer inquiries

Related Regulations

• EU Conflict Minerals Regulation
• EU Battery Regulation
• REACH (SVHC)
• German Supply Chain Act (LkSG)
• UFLPA
• SEC Climate Disclosure

Managing conflict minerals alongside related supply chain due diligence eliminates duplicate outreach. Certivo validates supplier submissions across multiple frameworks.

Industries Most Impacted

Your Pain Point: 3TG in every PCB, connector, and solder joint; thousands of components

Your Pain Point: OEM flowdown requirements; IMDS integration needs

Your Pain Point: DFARS requirements; high-reliability applications

Your Pain Point: FDA supply chain expectations; complex assemblies

Your Pain Point: Long product lifecycles; legacy supplier relationships

Your Pain Point: Cobalt and extended minerals requirements emerging

Your Pain Point: Gold sourcing scrutiny; brand reputation risk

Your Pain Point: Upstream materials; high supplier complexity

Return on Investment

90%

Reduction in Compliance Labor

From Months to Days

4 hours

To Customer Response

Form SD Documentation Acceleration

Real-Time

RMAP Sync

Proactive Smelter Monitoring

Key Statistics

• 4 Conflict minerals (3TG) traced to smelter level
• 300+ RMAP conformant smelters validated automatically
• 95% Supplier response rate with CORA-powered campaigns

Frequently Asked Questions

• How does Certivo handle different CMRT versions and formats?
  CORA-driven compliance intelligence parses CMRTs in any version—current RMI templates, legacy versions, and custom supplier formats. The system extracts smelter IDs, names, and countries regardless of template structure, normalizing data for consistent validation.

• Can Certivo validate smelters against the RMAP conformant list automatically?
  Yes. Certivo maintains continuous sync with the RMI conformant smelter and refiner database. When suppliers submit CMRTs, the platform validates every smelter against current conformance status and flags non-conformant, unknown, or delisted facilities.

• Does Certivo support both US SEC and EU conflict minerals requirements?
  Yes. Certivo supports Form SD documentation for SEC-reporting companies and OECD five-step due diligence for EU importers. Single supplier CMRT collection satisfies both regulatory frameworks without duplicate outreach.

• How does Certivo help with Reasonable Country of Origin Inquiry (RCOI)?
  Certivo documents your RCOI process with complete audit trails—supplier outreach records, response tracking, smelter validation results, and risk assessment documentation. This evidence supports your Form SD filing and demonstrates good-faith due diligence.

• How does Certivo compare to spreadsheet-based conflict minerals programs?
  Certivo replaces reactive, manual CMRT tracking with proactive, automated supplier outreach, CORA-powered smelter extraction, and real-time RMAP validation. As your system of record for conflict minerals evidence, Certivo eliminates the annual scramble and provides continuous visibility into your 3TG supply chain.