Conflict Minerals - Tin Suppliers CMRT

#1
Hoping this is an applicable forum for this question. We're doing our due diligence with a tin plating supplier, who forwarded their tin metal supplier's CMRT. They stated in CMRT question 3 they source from the covered countries and provided the usual list of smelters, but none of the covered countries seems to be listed. Our tin plater's supplier answered "Yes" to CMRT questions 3 & 4 and included this comment:
The RMI allows for approved concentrates to be responsibly sourced from the DRC and surrounding covered areas. Smelters that source these approved concentrates from these areas are considered "approved, level 3 smelters" for RMI and reporting purposes. Nathan Trotter's policy follows the Dodd Frank legislation and corresponding RMI approved smelters, and therefore may source material from approved level 3 smelters.

This is the first time I've seen this "disclaimer" before. Has anyone else seen this from your supply chain? Is it legit?

Thanks in advance!
 
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#3
John, thanks very much for your reply. It covers my situation very well. I've been responsible for Conflict Minerals from the outset and was under the impression that any source in the DRC and adjoining countries was conflict-related. This is the first time I've seen my supply chain reporting "due-diligence exceptions". Thanks again and hope you have a happy 4th!
 

sandra2014

Involved In Discussions
#4
Hello, We are a wire & cable harness contract manufacturer, we provide our clients with a declared company level CMRT file. we update our CMRT file with supplier CMRT files. Our clients have noted suspect smelter listing in our CMRT file. Upon investigation we identified the distributor (supplier), and contacted them for response. Our supplier is submitting product level CMRT's for the suspect smelters to us. Are we required to update these supplier product CMRT's to our own company level CMRT file?, or should we just send the supplier product CMRT files to our clients? We do not add any material to our clients product, our clients are responsible for the design of their product. And since we are a contract manufacturer, are we required to fully comply with the Responsible Minerals Initiative (RMI), and Section 1501 of the U.S. Dodd-Frank Wall Street reform act? Please advise,
Thank You for your help!
 

Ninja

Looking for Reality
Trusted Information Resource
#5
Hello Sandra,
If you don't source material except from your customer (assuming your customer is not in a conflict region), it seems to be down to CYA only.
It's a great question for counsel...
 

SpinDr99

Involved In Discussions
#6
I'm new at CMR and would appreciate any and all guidance with respect to how to complete the template. Is this for singular customers or ALL customers? If it were for one customer at a time, it seems like I'd be filling out templates for eternity. And if it were for all customers, getting information on mines, smelters, smelter classifications etc. would also take eternity. I had one supplier tell me they do one product at a time.
Do the suppliers actually know the smelters and their classifications?
If they flow it up to their suppliers, it seems like we're all at the mercy of those above us, probably several levels up.
I'm a one-man show at an electronics component distributor and I'm hoping someone can help me simplify this seemingly monumentous task.

Much appreciation to all respondents in advance!!!
 

Ninja

Looking for Reality
Trusted Information Resource
#8
3TG is all I've seen, at least recently... and as far as I've seen it IS per customer (per customer who asks for it).
Save it as a word or editable pdf template...and just fill in the party of concern...

I've found that it is entirely based on what your supplier reports to you...you don't get to know their smelters or mines...you just get to see their attestation.
...and yes, if anyone in the long chain lies about it, everything downstream is contaminated...
As above, it is worth running it by counsel.
 

Tagin

Trusted Information Resource
#9
If it were for one customer at a time, it seems like I'd be filling out templates for eternity. And if it were for all customers, getting information on mines, smelters, smelter classifications etc. would also take eternity.
For your situation, you would usually do a single company-level CMR, which can be given to all customers.

Note that your CMR is a "best-effort" declaration. One of the questions on the CMRT asks: what percentage of suppliers have responded to you? So, while it would be nice for it to be complete, its not required, unless you have a customer that is an absolute stickler.

Am I to understand correctly that reporting is ONLY required for the 4 identified minerals?
Cobalt is starting to become a fashionable thing to ask for:
Cobalt Reporting Template
 
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