How to Get Suppliers to Return a Valid CMRT
Founder & CEO Published Oct 16, 2026
A supplier’s CMRT is valid when it passes four checks:
- It is on a current RMI template version. The current version is CMRT 6.6, released on 17 April 2026. Some customers set their own minimum and reject anything older.
- The Declaration tab is complete, with no open errors on the Checker tab.
- The scope matches what you asked for. If you asked about your parts, a company-wide answer is not the same thing.
- The smelter list agrees with the answers. Every metal the supplier says it uses has smelters listed, with names and RMI identifiers where they exist.
Most rejected CMRTs fail one of these four. You will get more valid files on the first pass if you name all four in your request, check each return the week it arrives, and send it back with the exact problem named.
What is the CMRT?
The Conflict Minerals Reporting Template is a free Excel file from the Responsible Minerals Initiative (RMI). It moves information about tin, tantalum, tungsten, and gold (3TG) up the supply chain: whether a supplier uses them, which countries they come from, and which smelters and refiners process them.
The main tabs are:
- Declaration. Company details, the declaration scope, questions about each metal, and company-level questions A to H.
- Smelter List. Each smelter or refiner in the supplier’s chain, by metal.
- Product List. The products covered, when the scope is product-level.
- Checker. Flags required fields that are still empty.
- Smelter Look-up. RMI’s reference list of known smelters at the time the template was issued.
US-listed companies use CMRTs to support their Form SD filing under the SEC conflict minerals rule. EU importers of 3TG use them under the EU Conflict Minerals Regulation. If you are a private contract manufacturer, you probably file neither. Your customers do, and they write the CMRT into their supplier terms. You then need CMRTs from your own suppliers to build the one you send back.
Which CMRT version should suppliers use?
Ask for the current version, and say so in the request. RMI released CMRT 6.6 on 17 April 2026. The previous version, 6.5, came out on 25 April 2025. RMI has updated the template about once a year recently, and the next update is expected in spring 2027.
Version 6.6 did not change the reporting scope. It added two Product List fields, Requester Product Number and Requester Product Name, and it refreshed the built-in smelter reference lists.
Customers decide what they accept. ABB’s supplier training says any version below its stated minimum will be rejected. Other customers accept anything from 6.0 up. Find the strictest minimum among your customers and ask suppliers for that version or newer. Attach the blank template to the request so nobody fills in an old copy from a shared drive.
A new version in April can land in the middle of your season. Do not re-ask suppliers who already sent a valid file on the prior version, unless a customer requires it.
What makes a returned CMRT invalid?
These are the errors that come up again and again, in customer guidance and in companies’ own SEC filings.
| Error | What it looks like | What to ask the supplier to fix |
|---|---|---|
| Old template | A 5.x or early 6.x file, often reused from a past year | Re-enter the data on the current template |
| Checker errors | Required fields still flagged on the Checker tab | Complete every flagged field until the Checker shows none remaining |
| Missing company details | No authorized contact, no email, or no completion date | Add a named authorized signer and the date |
| Questions skipped | Questions 1 and 2 answered “yes” for a metal, but the rest of that metal’s questions left blank | Answer every question for any metal that is used and remains in the product |
| Company questions skipped | A to H blank when a metal is used | Answer A to H |
| Scope mismatch | ”Company” scope when you asked about specific parts, or “Product” scope with an empty Product List | Use the scope you asked for and list the products |
| Smelters missing | Metals marked as used, but no smelters listed | List the smelters, or explain in the comments why they are unknown |
| Smelter details incomplete | Names with no smelter ID, or “smelter not listed” with no country | Use RMI’s identifier where one exists. For unlisted smelters, give the name and country |
| Not a smelter | Traders, distributors, or the supplier’s own vendors on the smelter list | Remove them and list the actual smelters or refiners |
| Answers contradict the list | Question 1 says “no” for a metal, but smelters for that metal appear | Correct whichever entry is wrong |
| Stale | A file dated in a prior reporting year | Confirm the data still holds, and re-date or update it |
SEC filers report the same problems in public. Lucid wrote that most of its in-scope suppliers responded “at a company-level” without information specific to its products, in its 2025 Conflict Minerals Report. AMSC reported that many responses were company-level CMRTs or did not name the smelters, in its 2025 report. If large filers struggle with this, plan for it in your own supply base.
Why does company-level versus product-level scope matter?
A company-level CMRT covers everything the supplier makes. Its smelter list is the union of every smelter in every product line. That tells you little about the parts you buy. It can also overstate your exposure, because it pulls in smelters that never touch your parts.
A product-level CMRT covers the products you name. Its smelter list applies to them. That is what your customers usually want when they ask about their parts, and what you need to build a product-level CMRT of your own.
Company-level answers are not always wrong. A small supplier making one product family may have one answer for all of it. But you should choose the scope, not the supplier. State it in the request: “Please complete the CMRT at product level for the part numbers listed below.” List the part numbers. Version 6.6’s new Requester Product Number field gives the supplier a place to enter your numbers directly.
When does the CMRT collection season run?
The season follows the US Form SD deadline. Form SD is due on 31 May each year, or the next business day. For calendar year 2026, it is due on 1 June 2027, because 31 May 2027 is Memorial Day. Your customers work back from that date, and you work back from theirs.
| When | What happens |
|---|---|
| October to December | Customers plan. You confirm which suppliers are in scope and fix bounced or stale contacts |
| January | Customers send requests. You send yours to your suppliers the same month |
| February to March | Follow-ups. First returns arrive and need checking |
| Late March to early May | Supplier deadlines in customer programs typically fall in this range |
| Mid-April | RMI often releases a new template version |
| May | Customers roll up returns and file. Late suppliers become your problem |
The calendar is tighter than it looks. Customer deadlines for you are often weeks before their own filing. Semtech, for example, asks suppliers for a CMRT within 15 days of request. If you start your own supplier requests in March, you will miss.
Contact work belongs in the fall. A request sent in January to the person who left last summer costs you weeks. Check your contact list before the season starts. See how to find the right contact at a supplier.
How do you follow up so the CMRT comes back valid?
Follow-up is not only about getting a reply. It is about getting a file you can use. Here is a sequence that works.
- Send to the person who owns it. That is usually quality, compliance, or the person who filled in last year’s CMRT. A sales inbox will forward it, slowly.
- Make the first request complete. Attach the blank current template. Name the minimum version, the scope, the part numbers, and the due date. Say what the file is for.
- Check each return within a few days. Open the Checker tab. Compare the scope to what you asked. Read the smelter list against the answers. Do not mark it received until it passes.
- Send it back with the exact problem. “The Checker tab shows three required fields open on the Declaration tab” gets fixed. “Please review your CMRT” does not.
- Change contacts when someone goes quiet. After two follow-ups with no answer, find another person at the supplier. Quality managers, the account manager on your purchasing side, or the supplier’s own compliance lead are good second choices.
- Escalate through purchasing for the last few. A buyer who mentions the next purchase order gets attention that a compliance email does not.
- Track status per supplier. For each one, record the contact, the last touch, and where the request stands: sent, returned, rejected and sent back, or valid.
Some suppliers will never return a perfect file. Record what you have, what is missing, and what you did to get it. A documented, good-faith inquiry is what the SEC rule and the OECD Due Diligence Guidance expect.
What do you do with the valid files?
Roll them up into your own CMRT. Combine the smelter lists, remove duplicates, and answer the declaration questions for your own scope. Then check your rolled-up smelter list against RMI’s facility lists to see which smelters are conformant. Keep each supplier’s file. Your customers may ask for the evidence behind your answer.
Is the conflict minerals rule going away?
Not yet. A House bill to repeal the SEC rule, H.R. 7085, was reported out of committee in March 2026. As of October 2026 it had not had a floor vote. The SEC rule still applies, and so does the EU regulation. Many OEMs also ask for CMRTs as a customer requirement, not only for SEC filing. Plan the 2027 season as normal.
TL;DR
What is the current CMRT version?
CMRT 6.6, released by RMI on 17 April 2026. The next version is expected in spring 2027.
What is the most common reason a CMRT is rejected?
Incomplete Declaration fields that the Checker tab flags, followed by scope and smelter list problems.
Should I ask for company-level or product-level?
Product-level for the parts you buy, unless the supplier makes one product family or your customer accepts company-level.
When should I send CMRT requests?
In January, after cleaning up contacts in the fall. Expect customer deadlines from late March to early May.
Sources
- RMI Conflict Minerals Reporting Template. The template and its instructions.
- RMI facility lists. Smelter and refiner status for checking returns.
- SEC Form SD. The annual filing and its 31 May due date.
- Regulation (EU) 2017/821. The EU Conflict Minerals Regulation.
- OECD Due Diligence Guidance for minerals. The due diligence framework both laws point to.
- CDX notice on CMRT 6.6 and EMRT 2.11 and Q Point on the 6.6 release. Release date and changes.
- ABB supplier CMRT training. An example of a customer rejecting old versions.
- H.R. 7085 on congress.gov. Status of the repeal bill.
Bridgecurrent sends CMRT requests from your own email, follows up, finds a better contact when someone goes quiet, and sends back any CMRT that fails the check. See pricing.