Does a chemical supplier have to fill out a CMRT for customers?
Summary
Only if a customer asks: Dodd-Frank Section 1502 binds SEC-reporting issuers, so a chemical supplier answers the CMRT as a customer requirement. The exception is a supplier that is itself an SEC issuer or imports Annex I tin, tantalum, tungsten or gold into the EU above the volume thresholds of Regulation (EU) 2017/821, since each carries its own legal duty.
SEC Rule 13p-1 applies to registrants that file reports under Exchange Act Section 13(a) or 15(d) and have conflict minerals necessary to a product they manufacture or contract to manufacture (SEC, 2012).
Form SD covers a calendar year and is due on 31 May for the prior calendar year (SEC, 2021).
EU importers of tin, tantalum, tungsten and gold must carry out due diligence from 1 January 2021 under Regulation (EU) 2017/821 (European Commission, accessed 2026), unless their annual import volume is below the Annex I thresholds (European Union, 2017).
The SEC does not treat a conflict mineral used as a catalyst as necessary to production if it is not contained in the product (SEC, 2012).
When does a chemical supplier have to fill out a CMRT, and when not?
A chemical supplier fills out a Conflict Minerals Reporting Template (CMRT) when a customer requires it by contract or purchasing terms, and has a legal duty of its own only as an SEC-reporting issuer or an EU importer of 3TG (tin, tantalum, tungsten and gold). The CMRT is a free template from the Responsible Minerals Initiative (RMI) for passing mineral origin and smelter data through the supply chain (RMI, accessed 2026). Neither Section 1502 nor Rule 13p-1 places a filing duty on a private supplier; the request reaches you because your customer must trace the 3TG in its own products back to smelters and refiners. The condition table below decides whether and how to answer a CMRT request.
Situation | Verdict | Why |
|---|---|---|
Customer is an SEC-reporting issuer | Answer the CMRT; you file nothing | The customer files Form SD by 31 May for the prior calendar year (SEC, 2021) |
Customer imports 3TG minerals or metals into the EU above the Annex I volume thresholds | Answer the CMRT if asked | EU importers above those thresholds carry due diligence duties from 1 January 2021 (European Commission, accessed 2026; European Union, 2017) |
Tin, tantalum, tungsten or gold compound intentionally added and remains in the product | Full CMRT with smelter list | Yes to the first two declaration questions |
3TG used only in production, none remains | CMRT with Yes to question 1, No to question 2, reason in comments | SEC excludes catalysts not contained in the product (SEC, 2012) |
No 3TG added or used | CMRT with No for each metal and a comment | The template still records the answer |
Raw material content unknown | Ask raw material suppliers first | A No based on assumption cannot be defended |
You are an SEC issuer or EU 3TG importer above the Annex I volume thresholds | Own legal duty beyond the CMRT | Rule 13p-1 or Regulation (EU) 2017/821 applies to you |
The key row is the first: a supplier to an SEC issuer answers the CMRT, but the Form SD filing stays with the customer. Where an answer cannot be supported yet, say so in the comments field rather than guess.
Which chemical products contain 3TG that a CMRT must report?
Chemical products report 3TG on a CMRT when a tin, tantalum, tungsten or gold compound is intentionally added to the product or used in its production. Organotin catalysts and stabilizers are one documented case. A commenter on the SEC conflict minerals rule described organometallic compounds, including catalysts, stabilizers and polymerization aids such as stannous octoate, monobutyl tin trichloride and dioctyltin dilaurate, used to make silicones, polyurethanes, vinyls and polyesters (SEC, 2012).
Form SD defines conflict minerals as columbite-tantalite, cassiterite, gold, wolframite or their derivatives, limited to tantalum, tin and tungsten (SEC, 2021). Check each SDS composition section, each formulation record and each raw material declaration for these metals, including additives present below SDS disclosure limits. A catalyst that stays in the product in trace amounts still counts for an SEC issuer, because the SEC treats a catalyst as necessary to production when it is contained in any amount, including trace amounts (SEC, 2012).
How do you fill out a CMRT when your chemicals contain no 3TG?
A chemical supplier whose products contain no 3TG fills out the CMRT company information and answers No to the first declaration question for each of tin, tantalum, tungsten and gold. That question reads "Is any 3TG intentionally added or used in the product(s) or in the production process?" (Astemo Americas, 2025).
Choose the declaration scope the customer asks for: company, product or user defined. Product scope lets you list the products the answer covers. Write a short comment for each No, naming the basis, such as the formulation and raw material declarations reviewed. Some customers require it: one automotive buyer's published instructions say a supplier must enter a comment explaining "No" responses (Astemo Americas, 2025). Use the latest CMRT version listed on the RMI website; the same buyer accepts the latest approved version stated there (Astemo Americas, 2025).
Question 2 is required for each metal answered Yes to question 1, and the smelter list for each metal answered Yes to question 2 (Astemo Americas, 2025). Enter the effective date and a named authorizer, since a customer may direct its follow-up questions to that contact (Astemo Americas, 2025).
What evidence should back a chemical supplier's CMRT answers?
A chemical supplier's CMRT answers should rest on the formulation record, the SDS composition for each product, and written declarations from raw material suppliers on 3TG content. A No answer for a metal should name which of these was checked and when.
For a Yes answer, the smelter list comes from upstream: ask the raw material supplier for its own CMRT and copy the smelter names and identification numbers. Where a raw material supplier does not answer, mark the metal as unknown and record the follow-up, rather than answering No. The same discipline applies when you answer a customer's supplier quality questionnaire: reply in the customer's format and keep the evidence behind every answer. Recheck the evidence when a formulation or raw material source changes, because the last CMRT then no longer describes the product.
In Lubinpla, a technical inquiry reply splits a customer's request such as a CMRT into its items and fixes the supporting evidence for each item before the answer is written. Keep the CMRT, the cover letter and the evidence together, dated, so a reviewer can trace each answer.
Frequently asked questions
Is a no-3TG declaration letter enough instead of a CMRT?
A letter is enough only when the customer says it will accept one. One automotive buyer names the CMRT as its approved tool for suppliers to document their conflict minerals declaration (Astemo Americas, 2025). Send the completed CMRT with a short cover letter naming the products covered and the basis for each No answer.
Do conflict mineral rules cover cobalt or mica?
The SEC rule covers tantalum, tin, tungsten and gold, and Regulation (EU) 2017/821 covers the same four. Cobalt and mica are covered by a different RMI template, the Extended Minerals Reporting Template (RMI, accessed 2026), which a customer may send as a separate request.
How often should a chemical supplier update a CMRT?
Update the CMRT when a customer asks, when a formulation or raw material changes, and when RMI releases a new version that the customer requires. Form SD covers a calendar year (SEC, 2021), so many customers send requests early in the year.
Can a distributor answer a CMRT for products it does not make?
A distributor can pass on the manufacturer's CMRT or ask the manufacturer for one. It should not fill in answers it cannot support from the manufacturer's records.