CMRT vs EMRT: 8 Checks on the File Your Component Supplier Sends

A CMRT is a free spreadsheet from the Responsible Minerals Initiative (RMI) that reports which smelters supplied a company's tin, tantalum, tungsten and gold, known together as 3TG. An EMRT does the same job for cobalt, copper, natural graphite, lithium, natural mica and nickel. As of November 2026 the current revisions are CMRT 6.6 and EMRT 2.11, both released on 17 April 2026. Neither file tells you which smelter fed the reel on your bench, so a buyer's job is to test what the supplier actually declared.

CMRT, EMRT or AMRT: match the file to the metal

Ask for a CMRT when your customer's concern is 3TG, an EMRT when it names cobalt, mica or the other four extended minerals, and an AMRT only when it lists a specific further mineral. If the request says "conflict minerals", it means the CMRT. If it says "responsible minerals", ask which template before you chase anyone, because the CMRT and EMRT are separate files with separate smelter lists.

The EU regulation probably does not name you, but your customer's contract does

Regulation (EU) 2017/821 binds EU importers of tin, tantalum, tungsten and gold as ores, concentrates or processed metals, and its importer requirements have applied since 1 January 2021. The European Commission says companies working beyond the metal stage have no obligations under it. A reel of capacitors is well beyond the metal stage, so a German buyer of finished parts is not the party that DEKSOR, the national control body at the BGR, is checking, unless you also import metals.

The pressure arrives through purchase terms instead. An EMS in Bavaria building boards for a US-listed OEM will get the request because that OEM files a Form SD with the SEC under Rule 13p-1 each May and needs data from its whole chain. Your customer's instructions on revision, scope and deadline therefore outrank any general advice, including this article. Read them first.

Eight checks on the file before it goes in your folder

A CMRT passes when its revision, date and scope fit the request and its answers agree with its own smelter list. Run them in this order, because the first three decide whether the rest are worth your time.

1. Revision. The first tab shows it. Expect 6.6 on a new request. An older completed file remains a valid record for its own period, and whether it is acceptable now is your customer's call. A revision 6.5 file dated early April 2026 was simply issued days before 6.6 appeared.
2. Effective date. It is a mandatory field. Our working rule is to go back to the supplier if the date is more than 12 months old, unless the customer allows longer.
3. Declaration scope. The options are company, product or user-defined. A company-level file speaks for everything that company sells. A product-level file only helps you if your exact ordering code appears on the Product List tab, so search for it.
4. Questions 1 and 2, per metal. These ask whether any 3TG is intentionally added and whether any remains in the product. A "No" on tin from a maker of tin-plated terminations is a contradiction worth an email. A blanket "Yes" on tantalum in a company file says nothing about a polymer aluminium part such as Panasonic EEF-HX1A101R (69,500 in GlobX stock as of 9 November 2026), which has no tantalum dielectric.
5. Questions 3 and 4, covered countries. A "Yes" is not a failure. In Microchip's report for 2025, 14 of 33 tantalum smelters behind its main product category were known or suspected to source from covered countries, while 32 of the 33 were RMAP conformant. What matters is whether those smelters passed assessment.
6. Question 6, supplier response rate. The form answers this in bands, and "Greater than 50%" is a real answer on files in circulation. Microchip reports 100% from suppliers of its main product category and more than 82% for its second category, where discrete component makers sit several tiers down. If a small reseller claims 100% across hundreds of brands, ask how it got there.
7. Question 7 against the Smelter List tab. A "Yes" to identifying all smelters needs real rows behind it. RMI says placeholders such as "Unknown Smelter" or "TBD" do not correspond to valid smelter IDs, and that suppliers should complete them before finalising. A "Smelter not listed" row must still carry a name and country.
8. Checker tab and company questions. The Checker tab lists mandatory cells left empty. Question B asks whether the sourcing policy is public and requires the URL in the comment field, so open it. A dead link on a file signed this year tells you how much care went in.

What a distributor's CMRT can and cannot prove

A distributor's CMRT shows that the distributor surveyed its suppliers. It cannot show which smelter supplied your lot, and nor can a manufacturer's file. Microchip states that for all its product categories it has been unable to conclusively determine the origin of the 3TG in its products, because suppliers reported at company or large product family level. That report lists 206 smelters for its main category and still stops short of lot level.

So on a multi-brand order, a single roll-up from your distributor is the weakest thing to file. The stronger pair is the current manufacturer's declaration plus a certificate of conformance tying your lot to that manufacturer. On open-market stock, the manufacturer's CMRT only applies if the parts are genuine, which is why AS6081 sourcing controls sit in front of the paperwork. A broker who cannot say where the parts came from has given you no minerals data at all, whatever the spreadsheet says.

Legacy brands: ask the company that owns the line today

For parts still marked with an acquired brand, the declaration comes from the acquirer: Microchip for Atmel, Analog Devices for Maxim, Infineon for Cypress. An Atmel or Maxim file from before the acquisition describes a supply chain that no longer exists. These are four lines from GlobX stock and where each trail leads as of 9 November 2026.

The trap on obsolete stock is the date. A 2025 report describes the 2025 supply chain, and it does not describe a lot built in 2017. Do not imply that it does. Use the comment cell to record the part's date code next to the reporting period you relied on, and tell your customer about the gap before they find it. If the original maker no longer exists and no successor took the line, a written statement explaining that is the honest answer, and your customer decides whether to accept it.

Put the requirement on the RFQ, not in a chase email

Flag minerals reporting per BOM line at quote stage, because a declaration requested after the purchase order has no commercial weight behind it. Add these five items to the request, alongside your BOM scrub and REACH declarations:

• Template and revision required, with CMRT and EMRT stated separately.
• Scope required: company level or product level, with the exact ordering code if product level.
• Reporting year your customer is collecting.
• Deadline, set at least two weeks ahead of your customer's date.
• Whether a written statement is acceptable when no template exists.

Add one column to your BOM headed "CMRT needed" and send it through our quote form. Within 24 hours we will return stock and date codes, and tell you which lines come with manufacturer paperwork we can pass on and which need a request through the manufacturer's own portal. Our quality page sets out the inspection and traceability steps behind each shipment.