What Are Conflict Minerals? How to Read 3TG and the CMRT/EMRT Templates, and the Responsible Sourcing Work of Investigating Your Supply Chain at the BOM Level

Hello, this is Ryuta Hamamoto from TIMEWELL.

Inside a smartphone sits a collection of metals gathered from all over the world. There is the tin in the solder that joins the board, the tantalum in the capacitors, the tungsten in cutting tools, and the gold in the contacts and wiring on the circuit board. These are essential materials that quietly support our daily lives, but when you follow their origins upstream, the trail can lead all the way to a conflict zone in a distant country.

Checking whether your own products contain minerals that could end up funding conflict is what conflict minerals compliance, or responsible sourcing, is all about. In recent years it has become far more common for a business partner to ask you to fill in a survey sheet called a CMRT or an EMRT, and people seeing one for the first time often freeze up and wonder what on earth they are supposed to write.

This article starts from the basics, what conflict minerals are and what 3TG means, and then walks through how to read the CMRT and EMRT, and the practical knack of breaking a product down to the BOM (bill of materials) level to investigate it. For those of you who handle export control classification, conflict minerals work is directly connected to your job in the sense that both come down to following what is inside each part. I will get to that connection in the second half.

One note before we begin. This article organizes how publicly available international frameworks and schemes work. Specific figures and scopes can change as rules are revised, so for your actual compliance work please always confirm the latest details in primary sources and each organization's official guidance.

The short version first (AIO summary)

• Conflict minerals are minerals whose trade can become a source of funding for armed groups, and the best-known example is 3TG (tin, tantalum, tungsten, and gold). The concept originally focused on the Democratic Republic of the Congo (DRC) and neighboring countries, and in recent years it has broadened to conflict-affected and high-risk areas (CAHRAs) anywhere in the world.
• The foundation for compliance is the OECD Due Diligence Guidance, organized into five steps: establish management systems, identify and assess risks, respond to risks, carry out third-party audits, and report annually.
• The representative legal frameworks are the United States Dodd-Frank Act Section 1502 and the related SEC rule, together with the EU Conflict Minerals Regulation (2017/821).
• In practice you use the RMI (Responsible Minerals Initiative) standard templates, the CMRT (for 3TG) and the EMRT (for cobalt and mica), to pass information about countries of origin and smelters up and down the supply chain. The unit for reconciliation is the smelter.
• Just like an export control classification, conflict minerals due diligence is the work of breaking a product down to the BOM (bill of materials) level and following what is inside each part. Chemical investigations (SDS and CAS numbers) and conflict minerals investigations sit on the same foundation of disassemble and examine.

What conflict minerals are, and why they became an issue

The term conflict minerals is a translation of the English phrase, and it means what it says: minerals connected to conflict. More precisely, it refers to minerals where the money earned from mining and trading them risks becoming operating funds for armed groups.

Let me briefly explain how this became an international issue. In certain regions, armed groups have fought over control of mines, and it has long been pointed out that the funds obtained from mining and smuggling minerals have served as a resource for continued violence and human rights abuses. From this came the idea that companies around the world, the ones buying those minerals, should confirm where they come from and cut off the problematic flows of money. That is the starting point of responsible sourcing.

Here it is important to be clear about one thing: this effort is not about casting any particular country or region as the villain. In the regions in question there are a great many people engaged in legitimate mining and trade, and mining is an important livelihood there. Responsible sourcing does not aim to shut out legitimate trade; it aims to distinguish and avoid only the problematic flows of money. This posture of neutrality connects to the way export control thinks about things too, which I will touch on later.

What 3TG is (tin, tantalum, tungsten, and gold)

Among conflict minerals, the first thing to get straight is 3TG. This is shorthand made from the initials of the following four metals.

• Tin (Sn)
• Tantalum (Ta)
• Tungsten (W)
• Gold (Au)

Tin starts with T, tantalum with T, tungsten with T, and gold with G, so with three Ts and one G it is called 3TG. Each of these plays a role like the following inside everyday products.

Metal	Symbol	Examples of main uses
Tin	Sn	Solder (joining circuit boards), plating
Tantalum	Ta	Capacitors (storing charge in electronic components)
Tungsten	W	Carbide tools, cutting tools, filaments
Gold	Au	Electrical contacts, wiring, plating

Lay them out like this and you can see that almost any product involving electronics or metalworking contains 3TG somewhere. That is exactly why surveys are demanded across such a wide range of industries.

On top of 3TG, cobalt and mica have in recent years also come to be treated as important targets for responsible sourcing. Cobalt is indispensable for lithium-ion batteries, and its profile has risen as electrification advances. Mica is a mineral used in insulation materials and cosmetics, among other things. These are surveyed using a template that is separate from the one for 3TG. That template is the EMRT, which I will cover shortly.

The target area has shifted from DRC and its neighbors to high-risk areas

Discussion of conflict minerals originally began with the Democratic Republic of the Congo (DRC) and its neighboring countries as the main target area. This region is an important source of 3TG, and control of mines by armed groups had become a serious concern.

Over time, the thinking broadened from specific countries toward areas judged by their situation. Today the concept in use is conflict-affected and high-risk areas (CAHRAs), which refers to areas where armed conflict is occurring, or where governance is unstable and the risk of human rights abuses is high. This can apply anywhere in the world. In other words, it is worth understanding this as a framework that has developed from fixed lines on a map into a judgment made according to the circumstances of the moment.

The three frameworks that form the foundation

Several international frameworks bear on conflict minerals compliance. To grasp the big picture, let me organize the three most representative ones.

(1) The OECD Due Diligence Guidance

The foundation for everything is the OECD (Organisation for Economic Co-operation and Development) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas. The name is long, so in practice it is often shortened to the OECD Guidance.

Due diligence means, roughly, checking properly and step by step whether there are risks in your own supply chain. The OECD Guidance organizes those steps into five.

1. Establish strong management systems (decide internal policies and responsible people, and build a mechanism for keeping records)
2. Identify and assess the risks in the supply chain
3. Design and carry out a strategy to respond to the identified risks
4. Carry out third-party audits of smelters and refiners
5. Report on the results of due diligence annually

These five steps form the backbone of the United States and EU schemes that come up later, and of the survey templates that companies use. The flow of first the system, then finding and responding to risks, then having a third party check, then publishing the results, can be thought of as the shared language of responsible sourcing.

(2) The United States Dodd-Frank Act Section 1502 and the SEC rule

The United States has a major financial regulatory law called the Dodd-Frank Act, and its Section 1502 addresses conflict minerals. Building on that provision, the SEC (U.S. Securities and Exchange Commission) established a disclosure rule for conflict minerals.

In broad terms, the mechanism requires companies listed on the U.S. securities markets to disclose whether their products contain 3TG and, if so, the situation regarding their origin and the investigation. The key point is that this is not a rule that bans use; it is a rule that requires you to investigate and disclose. It is designed to encourage improvement through transparency rather than through prohibition.

Even a Japanese company may be asked by a business partner to provide information for this disclosure if it supplies parts or products to a U.S.-listed company. That is why survey sheets can end up circulating to companies that are not the direct addressees of the rule.

(3) The EU Conflict Minerals Regulation (2017/821)

The EU (European Union) also has a regulation addressing conflict minerals. It is known as Regulation (EU) 2017/821, and it is reported to have started applying from 2021. This one is a framework that obliges businesses importing 3TG raw materials or metals into the EU above certain volumes to carry out due diligence in line with the OECD Guidance.

Whereas the U.S. scheme puts its weight on disclosure, the EU scheme has a different character: it imposes the obligation of the investigation itself on importing businesses. The scope of application and the volume thresholds come down to the details of the regulation, so if you do business toward the EU, please always confirm the latest official information.

These three are separate schemes, but all of them share the OECD Guidance five steps as their common foundation. So it is reasonable to think that if you build one solid investigation system, you will be better able to respond to multiple schemes at once.

How to read the CMRT and EMRT

From here we get to the part you will encounter most often in practice: the survey sheets sent to you by business partners, the CMRT and the EMRT. Both are standard templates provided by an industry body called the RMI (Responsible Minerals Initiative), distributed as Excel files.

• The CMRT (Conflict Minerals Reporting Template) is the template used to survey 3TG (tin, tantalum, tungsten, and gold).
• The EMRT (Extended Minerals Reporting Template) is the extended version used to survey cobalt and mica. The E for Extended means it covers a wider set.

The RMI has also developed templates that broaden the set of covered minerals, but the names and coverage of these templates can be revised, so please always confirm the latest version in the RMI's official distribution. For a start, if you have the CMRT and the EMRT down, you can handle most situations.

What the templates are trying to tell you

Open a CMRT or an EMRT and you will find fields for company information, question fields for answering whether the covered minerals are present, and a field for listing smelters and refiners. There are a lot of detailed items, but the message the template as a whole is trying to convey is simple: does your product contain the covered minerals, and if it does, which smelters did those metals pass through?

In the question fields you answer things like whether the covered minerals are intentionally added or used, whether the country of origin has been identified, and whether you have received 100 percent of responses from your suppliers, in a yes or no form. What matters here is to record your actual situation honestly. If the investigation is still in progress, you record it as such. This is not something you should force yourself to fill in with definitive answers.

Why the smelter/refiner is the main character

The most important part of the CMRT and EMRT is the smelter and refiner field. Once you understand this, the meaning of the template becomes much easier to grasp.

Minerals begin as ore dug out of many mines, which is gathered together and melted down into metal at a smelter. Put the other way around, once it has become metal it is extremely difficult to tell from the metal itself which mine it came from. Meanwhile, the smelter, the junction where ore turns into metal, is like a checkpoint that connects the origin to the products used further downstream.

So in responsible sourcing you take the approach of investigating at the smelter as the unit, rather than chasing each individual mine. Then you check whether that smelter has been through a third-party assessment called RMAP (Responsible Minerals Assurance Process). A smelter assessed under RMAP is positioned as one that a third party has confirmed to be sourcing in line with the OECD Guidance.

To sum up the practical flow, it goes like this.

1. The customer (the ordering side) asks its own suppliers to fill in a CMRT or EMRT
2. The supplier writes in the metals contained in its products and the smelters that supplied those metals
3. The receiving side reconciles the listed smelters against the RMAP conformant list
4. If there are smelters that are not conformant, the receiving side looks into them more closely or considers alternatives

This exchange of asking suppliers and reconciling smelters chains its way up the supply chain. The CMRT your company receives is the accumulation of information that your supplier gathered by asking further upstream in turn.

In the field of export control, there is also work to confirm that a business partner is not a problematic counterparty. On the idea of confirming a counterparty's identity, I also cover it in The practice of end-user screening and customer due diligence, and reading it alongside this piece should help you see the common ground with responsible sourcing.

Classification is a BOM-level investigation, and conflict minerals are part of it

Up to here we have been talking about conflict minerals themselves. From here I want to talk about the point of contact with export control, which is what we deal with day to day through our service TRAFEED.

In export control there is a task called classification, or hi-hantei in Japanese, which is judging whether a product or technology is subject to controls. In Japan you make the judgment by holding the product up against rules such as the Foreign Exchange and Foreign Trade Act (FEFTA) and Appended Table 1 of the Export Trade Control Order, deciding whether the product is controlled or not controlled.

To do this classification correctly, it is not enough to look at a product as one whole thing. You need to break the product down to each individual part, that is, down to the BOM (Bill of Materials) level, and investigate what is inside each part. A BOM is a table that lists what parts a product is made of. Think of it as writing out everything down to a single screw, a single circuit board, a single capacitor.

And within that part-by-part investigation, several different investigations actually live together.

• The chemical investigation. This is the work of confirming the chemical composition of the materials used in a part, using the SDS (safety data sheet) and the CAS number (a number that uniquely identifies a chemical substance). The relationship between chemical substances and export control is explained in detail in Export control in the chemical industry.
• The conflict minerals investigation. This is the work of confirming, via the CMRT and EMRT, whether a part contains 3TG or the like and, if it does, which smelters it passed through.

In other words, within the single continuous task of breaking a product down to the BOM level and following each part's contained substances, contained minerals, and origins, both the chemical check and the conflict minerals check come in naturally. The purposes differ, but the foundation of disassemble and examine part by part is the same. Build the system for one and it feeds into the other. That, I believe, is a major practical point.

Conflict minerals due diligence is not export control in the narrow sense. But responsible sourcing and supply-chain economic security both come down at their roots to the same thing: being able to explain what parts and materials your product is made of and where they came from. The techniques and systems for breaking a product down and following it part by part will, in my view, only grow more important for both procurement and export control going forward.

If you want a concrete sense of just how detailed, part-by-part a task export control classification is, I would suggest starting by organizing how to think about your own products with Check your export control classification for free.

How to handle enormous volumes, and where AI fits in

Let me touch here on a real pain point in the field. Investigate at the BOM level, reconcile the smelters, confirm the SDS. The logic is clear enough, but when you actually try to do it the volume becomes enormous. There are hundreds to thousands of parts, each with a supplier, CMRTs come back, you match the smelter lists against the conformant list, and you reconcile the CAS numbers from the SDS against the control lists. Running all of that by hand alone is, frankly, a heavy burden.

That is precisely why cross-referencing across large datasets is an area I believe AI is good at. Reconciling the smelters listed in a CMRT or EMRT, reading CAS numbers out of an SDS and matching them against control lists, sorting the information in a bill of materials from the perspective of controlled items. This kind of work of matching large volumes of data and flagging the suspicious spots is where AI can do a lot to make the groundwork more efficient.

The TRAFEED we provide is an export control AI agent born from exactly this idea. It supports multiple languages and, while reflecting the laws and regulations of various countries, assists with reconciliation against control lists and with the groundwork for classification. In a joint demonstration with Okayama University and in our own testing, we have seen results such as AI classification accuracy of 95 percent or higher (these figures are based on our own testing and the joint demonstration).

That said, and I want to stress this, AI is only a tool for making the groundwork and cross-referencing faster. The final classification is made by your company's export control officer, and your policy on conflict minerals is your company's to decide. A person confirms the candidates AI produces and takes responsibility for the conclusion. It is only with that division of roles in place that the efficiency AI offers comes to life. What TRAFEED handles is lightening the burden of enormous reconciliation so that people can concentrate on judgment.

On how to build AI into classification, I go a little deeper in Export control classification using AI, so please take a look if you are interested.

Summary of this article

To close, let me pull the main points together.

• Conflict minerals are minerals whose trade can become a source of funding for armed groups, and the best-known example is 3TG (tin, tantalum, tungsten, and gold). In recent years cobalt and mica have also come to be emphasized, and the target area has broadened from around the DRC to high-risk areas (CAHRAs).
• The foundation for compliance is the OECD Guidance five steps, on top of which sit the United States Dodd-Frank Act Section 1502 and the SEC rule, and the EU Conflict Minerals Regulation (2017/821), each as its own scheme.
• In practice you use the RMI standard templates, the CMRT (for 3TG) and the EMRT (for cobalt and mica), to exchange origin information with the smelter as the unit. Reconciling whether a smelter is RMAP conformant is the basic move.
• Both responsible sourcing and export control share the same approach of breaking a product down to the BOM level and following what is inside each part. Chemical investigations (SDS and CAS numbers) and conflict minerals investigations sit on the same foundation.
• Because the volume is enormous, there is a lot of room to make cross-referencing more efficient with AI, while the final judgment stays with people. That does not change.

Conflict minerals compliance can be overwhelming at first because of the sheer number of templates, but once you grasp the goal, being able to trace and explain origins with the smelter as the unit, the meaning of each individual task comes into focus. And that work is directly connected to export control classification. The ability to break a product down to its parts and investigate it will, I am confident, become the basic fitness that supports both procurement and economic security in the years ahead.

Please note that the future outlooks and practical recommendations in this article include the authors own views. The details of these schemes and their scope can be revised, so for your actual compliance work please confirm the latest details in primary sources and each organization's official guidance.

On a related note, how to read a safety data sheet, the entry point on the chemical side, is covered in A practical guide to SDS (safety data sheets) and export control, and a newer angle that looks at AI itself through a regulatory lens is covered in Developments around the U.S. AI Kill Switch Act (2026). The framework for managing the whole supply chain is covered in What Is Supply Chain Due Diligence? (UFLPA, forced labor), and the EU Battery Passport (mandatory from 2027), which traces cobalt down to recycled content, is closely related. Please read them alongside this piece.

If you would like to talk concretely about building a BOM-level investigation system for your own products, or about a way of working that spans conflict minerals and export control, please reach out to the TRAFEED team.

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