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News about conflict minerals and reporting templates

Conflict minerals

The regulation of conflict minerals under the Dodd-Frank Act, as well as the accompanying reporting tools such as CMRT, EMRT, and AMRT (formerly PRT), are at the center of current developments. Companies should be aware of the following updates:

1. Dodd-Frank Conflict Minerals Rule: Heading for repeal?

  • In May 2025, SEC Commissioner Mark Uyeda strongly criticized the conflict minerals regulation under the Dodd-Frank Act, calling it ineffective and costly for US companies.
  • He cited GAO findings that the rule had made no discernible contribution to promoting peace in the DR Congo.
  • There was also discussion of partially suspending or even completely abolishing the rule in the interests of national security.

2. CMRT 6.5 released – next version in spring 2026

  • In April 2025, the Responsible Minerals Initiative (RMI) released CMRT version 6.5 with updated smelter lists.
  • CDX has implemented the integration into its platform.
  • The next CMRT version (v6.6) is expected in spring 2026.

3. EMRT 2.0 & 2.1 – Expansion to battery-relevant metals

  • EMRT 2.0 (April 2025) expands the scope of reporting to include copper, graphite, lithium, and nickel – including a new “Mine List” tab to support the EU Battery Regulation.
  • CDX has implemented this expansion.
  • EMRT 2.1 was released in October 2025, with additional features such as product number fields, clearer validation notes, and an optimized data structure.

4. PRT becomes AMRT – Version 1.3 is in the works

  • The PRT (Pilot Reporting Template) has been renamed the Additional Minerals Reporting Template (AMRT) – AMRT v1.2 was released in October 2024.
  • AMRT 1.3 was introduced in October 2025 – with German language support, new tabs (Smelter Look-up, Mine List) and fields for product reference.
  • The next AMRT version is expected in fall 2026.

5. Recommendations for action for companies

  • Monitor the regulatory situation: As the Dodd-Frank Conflict Minerals regime is being called into question, it remains essential to keep an eye on SEC announcements.
  • Keep reports up to date: CMRT v6.5 or early use of v6.6 as soon as it becomes available.
  • Implement EMRT 2.0/2.1: Highly recommended for companies with battery-related metals in their supply chain.
  • Use AMRT 1.3: For mineral additives beyond the usual 3TG/EMRT minerals.
  • Update CDX/material database: Ensure that platforms support the new templates and fields.

Do you or your employees need training on conflict minerals? Find the next training dates here.

Do you need support with reporting, for example? Then you can rely on our expertise and entrust all tasks to us with confidence. Simply make an appointment for a free solution check.

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