CMRT Regulatory Updates | Certivo Regulations

CMRT

May 2026

Guidance Update

RMI FAQ: New CMRT releases in April generally do not require re-surveying suppliers for the upcoming filing
RMI guidance clarifies supplier-survey timing when a new CMRT is released in April. Companies generally do not need to re-survey suppliers solely due to an April CMRT release for the upcoming filing cycle. Instead, companies should use the latest CMRT version available when initiating their annual survey and clearly state which CMRT version was used/allowed. This impacts annual CMRT data-collection planning, supplier communications, and documentation practices for SEC Form SD / downstream conflict minerals due diligence programs relying on CMRT submissions.
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Guidance Update

RMI CMRT template download page is gated behind Terms & Conditions; current version/release info not publicly extractable
RMI’s official CMRT landing/download page requires accepting Terms & Conditions and does not expose the current CMRT version number, release date, changelog, or direct download links in publicly extractable content. For compliance teams, this means CMRT version change control cannot be validated from the open page content alone; teams should reference this official landing page for controlled access to the latest CMRT and retain internal evidence (downloaded file metadata, screenshots, or controlled copies) to support supplier survey/version governance.
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April 2026

Guidance Update

RMI FAQ clarifies companies generally do not need to re-survey suppliers solely because a new CMRT is released in April
RMI published/maintains official downstream FAQ guidance stating that when RMI releases a new CMRT in April, companies generally should not re-survey suppliers specifically to force use of the new version for the upcoming filing. RMI indicates the April CMRT update is intended for the next year’s filing cycle; companies should use the most recent version available at the time they initiate their annual supplier survey and clearly state which CMRT version was used/accepted. Compliance teams using CMRT for supplier data collection should align annual survey timing and version-control statements accordingly to avoid unnecessary rework and to maintain auditable documentation of the template version relied upon.
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Reporting Requirement

RMI Releases CMRT Version 6.6
RMI released CMRT 6.6 on April 17, 2026, as the new industry-standard template for 3TG (tin, tantalum, tungsten, gold) conflict minerals reporting, replacing CMRT 6.5. Key changes include new Requester Product Number and Requester Product Name fields in the Product List tab for improved product-level tracking and supply chain data reconciliation, alignment with IPC-1755 Responsible Sourcing of Minerals Data Exchange Standard, updated ISO short names for countries/states/provinces, updated Smelter Reference and Standard Smelter Lists, and improved built-in validation rules. The CMRT supports compliance with Dodd-Frank §1502 and EU Conflict Minerals Regulation 2017/821.
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Reporting Requirement

RMI releases CMRT 6.6 with expanded product-level transparency fields
The Responsible Minerals Initiative (RMI) released Conflict Minerals Reporting Template (CMRT) version 6.6 on April 17, 2026 as part of a coordinated update to its responsible minerals reporting templates (alongside EMRT 2.11 and AMRT 1.31). CMRT 6.6 improves product-level transparency with expanded Product List fields and continues to cover the conflict minerals tin, tungsten, tantalum, and gold (3TG). Compliance teams using CMRT for supplier data collection should update internal SOPs, supplier instructions, and any portal/import validations to the v6.6 file, and align annual survey timing with the new release. RMI does not recognize modified versions not developed via its consensus process; companies should clearly state which CMRT version was used or accepted on each filing for auditability.
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Reporting Requirement

RMI states latest Mineral Reporting Template (MRT) suite versions (including CMRT) were released on 17 Apr 2026
RMI’s official MRT Introduction page states that the latest versions of the Mineral Reporting Templates (MRTs)—including the Conflict Minerals Reporting Template (CMRT)—were released on April 17, 2026. This is compliance-relevant because CMRT is the de facto industry-standard reporting template used to collect and exchange 3TG due-diligence data across supply chains (supporting downstream regulatory reporting programs such as SEC Form SD). Compliance teams should confirm supplier outreach, internal SOPs, and validation tooling reference the current CMRT release and use the corresponding RMI smelter/reference list resources linked from the MRT pages.
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Reporting Requirement

RMI Releases CMRT Version 6.6
RMI released CMRT version 6.6 on April 17, 2026, replacing CMRT 6.5. Key changes include: (1) Product List tab now includes 'Requester Product Number' and 'Requester Product Name' fields for improved traceability; (2) Updates to ISO short names for countries, states, and provinces; (3) Updated Smelter Reference List and Standard Smelter List; (4) Enhancements aligned with IPC-1755 without creating conflicts. CMRT 6.6 is the current standard for 3TG conflict minerals reporting under Dodd-Frank §1502 and EU Conflict Minerals Regulation.
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February 2026

Guidance Update

RMI FAQ updates/clarifies annual CMRT versioning and supplier re-survey expectations (April release cadence)
The Responsible Minerals Initiative (RMI) provides CMRT operational guidance for downstream companies on how to manage annual supplier data collection when new CMRT versions are released (typically in April). The FAQ clarifies that companies do not need to re-survey suppliers solely because a new CMRT is released; instead, companies should use the most recent CMRT version available when initiating their annual supplier survey and document which version was used/accepted. This affects CMRT version control, supplier campaign timing, and defensible documentation for customer and downstream due diligence expectations that rely on CMRT outputs.
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Public Comment

USTR Federal Register notice requests public comments on plurilateral critical minerals trade agreement (adjacent impact for CMRT supply chains)
USTR published a Federal Register notice seeking public comments on a potential plurilateral agreement addressing trade in critical minerals. While this is not a CMRT template or SEC Form SD rule change, it is directly adjacent to conflict minerals/CMRT programs because it may affect critical minerals supply chain expectations, sourcing constraints, and due diligence evidence used across mineral supply chains. The notice includes a comment deadline of March 19, 2026.
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June 2025

Guidance Update

JEITA publishes completion guidance highlighting CMRT 6.5 smelter look-up discrepancies and workaround
A JEITA CMRT completion guide (English PDF) documents a practical data-quality/validation issue for CMRT Rev. 6.5: some smelters (example noted for tin) may appear on a conformant smelter list but be absent from CMRT 6.5’s Smelter Look-up tab, which can trigger CID entry/validation errors. JEITA advises using the 'Smelter Not Listed' option and manually entering smelter details in such cases. Compliance teams using CMRT intake automation should ensure exception-handling for 'not listed' entries and adjust validation rules to reduce supplier rejection loops.
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April 2025

Guidance Update

RMI releases new standard suite for social, environmental, OHS and governance risks used alongside minerals due diligence programs
RMI announced release of a new “standard suite” intended to provide a common framework to assess environmental, social, occupational health & safety (OHS), and governance risks in operations and mineral supply chains. While not a CMRT template-version release, this update is directly relevant for CMRT programs because it can influence due diligence expectations and program alignment used alongside CMRT-based supplier outreach and risk evaluation.
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Guidance Update

RMI releases CMRT version 6.5 (template update primarily affecting Smelter Reference List)
The Responsible Minerals Initiative (RMI), the maintainer of the Conflict Minerals Reporting Template (CMRT), released CMRT v6.5 (reported release date: April 25, 2025). The research indicates the principal change is an update to the embedded Smelter Reference List/Smelter Look-up data. For CMRT-driven supplier due diligence workflows, this can require updating supplier survey packages, internal intake/validation logic, and reconciliation against current smelter IDs and statuses to avoid mismatches and data-quality issues.
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May 2017

Reporting Requirement

RMI CMRT template access/download page is gated behind Terms & Conditions (limits automated retrieval of current CMRT version)
The official RMI CMRT template page requires acceptance of Terms & Conditions before the CMRT file can be accessed/downloaded, and the publicly viewable content does not expose the current CMRT version or release notes without passing the gate. This is operationally relevant for compliance teams because it can affect automated template distribution, internal controls over which CMRT version is used in supplier surveys, and evidence collection for version traceability (e.g., documenting when/where the CMRT was obtained).
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Guidance Update

RMI FAQ clarifies CMRT April releases generally do not require re-surveying suppliers for the upcoming filing year
RMI guidance (Downstream FAQ) explains that CMRT updates are typically released in April and are intended for use in the next year’s filing cycle. The FAQ advises companies to use the most recent CMRT version when launching their annual supplier survey, document which CMRT version they accepted, and indicates companies generally do not need to re-survey suppliers solely because a new CMRT version is released in April for the upcoming filing. Compliance teams can use this guidance to set internal survey timing, version-control practices, and supplier outreach policies around CMRT annual updates.
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Guidance Update

RMI publishes CMRT Completion Guide (corresponding to CMRT Revision 5.0, released May 12, 2017)
RMI makes available a CMRT Completion Guide PDF that provides instructions/definitions and completion guidance for the CMRT (the guide explicitly corresponds to CMRT Revision 5.0 and notes the related CMRT release date of May 12, 2017). While not a recent update, this is authoritative guidance used by compliance teams to correctly complete CMRT fields and avoid validation/format errors in supplier responses.
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Guidance Update

RMI hosts CMRT Completion Guide document (legacy guide corresponding to CMRT Revision 5.0)
An RMI-hosted CMRT guide PDF is available on the official domain and provides completion guidance (including handling duplicates and smelter location distinctions). The research indicates this is a legacy guide (corresponding to CMRT Revision 5.0, released May 12, 2017) rather than a newly issued guide within the last ~30 days; however, it remains an authoritative reference for CMRT completion practices where still applicable.
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