CMRT 4.01a Released, with modified Smelter Reference List to remove errors!

Compliance

Further to our earlier piece on CMRT v4.0 (Refer the 2nd half of this article), we now share with you the changes made on CMRT v4.01a.

With ongoing feedback and several inputs from the suppliers and manufacturers, CFSI has now come up with CMRT v4.01a as on August 6, 2015, which supersedes all the older versions.

The CMRT v4.01a underwent the following changes in the “Smelter Reference List” tab. These changes were made for accurate smelter identification.

  • The gold smelter ‘Elemetal Refining LLC’s’ smelter Id has been rectified from CID001323 to CID001322.
  • Blank spaces have been removed from 4 standard smelter names.
  • The tin smelter ‘PT Supra Sukses Trinusa’ has been removed as it does not meet the CFSI definition of a smelter or refiner.
  • The gold smelters, ‘CCR Refinery – Glencore Canada Corporation’ and ‘OJSC ‘The Gulidov Krasnoyarsk Non-Ferrous Metals Plant (OJSC Krastvetmet)’ have been modified for typographical error.

The CFSI (Conflict-Free Sourcing Initiative) released the previous revision of the Conflict minerals reporting template (CMRT) on June 12, 2015. The CMRT v4.01 superseded the v4.0 which was released on April 30, 2015.

Also Read

Conflict Minerals Compliance: FREQUENTLY ASKED QUESTIONS

Basis the latest update CFSI now recommends CMRT v4.01a for collecting 2015’s supply chain data due to errors in CMRT v4.01. The CMRT v4.01a should be used for next SEC filing due May 31, 2016.

 CMRT v4.01 versus CMRT v 4.0

  • Declaration tab: The cell “I3” on CMRT v4.0 top right corner, shows an alert for more information even when all the necessary details are provided.
  • Smelter list tab: On selection of last two options (“Smelter not listed” or “Zhangyuan Tungsten Co Ltd”) from the smelter reference list available for Tungsten, the cell erroneously turns red.
  • Checker tab: The last 3 rows (“Smelter list- Tin”, “Smelter list- Gold”, “Smelter list- Tungsten”) turn green only when the smelter list is provided for Tantalum in the Smelter list tab.

 CMRT v4.0 versus CMRT v 3.02

The CFSI (Conflict-Free Sourcing Initiative) released the latest revision of the conflict minerals reporting template (CMRT) as of April 30, 2015. The CMRT v4.0 acts as a leading multi-industry tool which helps the manufacturers/suppliers to gather information through the supply chain regarding minerals used in their products, country of origin of the minerals, smelters and refiners used. The newer version of CMRT has been built such that it works across multiple softwares and operating systems. The tool has a simplistic structure to enable cross platform interactions.

The CMRT 3.0, 3.01 and 3.02 versions are recommended for the collection of 2014’s supply chain data and the standard smelter list of the CMRT v3.02 version needs to be considered to file under SEC in 2015.The CMRT v3.02 underwent major changes for the new release of the CMRT v4.0. To improve the accuracy of users’ disclosure, CMRT v4.0 keeps the users updated with the recent changes in the IPC standard and smelter list. Along with the updated smelter list it also shows numerous translation changes.

The changes that were observed in declaration and standard smelter names tab are discussed below:

Declaration tab:

The Company Information section remains unchanged on the tab but for the other sections like Sourcing and Policy Information slight modifications have been made on question 1-7 and A-J respectively. These changes are focused on the data collection of 3TG used instead of the broader category of conflict minerals.

Standard Smelter Names tab renamed as ‘Smelter Reference List’:

The renamed tab has been updated with commonly used alternate smelter names. For the selected metal and smelter name from the drop down, the Smelter City and the Smelter Facility Location loads automatically. This information would be helpful to have unique smelter data that will reduce ambiguity for the smelters that earlier had a multi-level facility reporting.

The standard smelter list of CMRT v3.02 contains 279 smelters out of which 274 are unique while the updated standard smelter list contains 290 unique smelters.

From the CMRT v3.02, 33 smelters were removed.

Based on the CFSI’s revision on CMRT v3.02, we have listed the changes observed from the CMRT v4.0.

Out of 290 unique smelters, 88 smelters were modified for the following reasons

  • 56 smelters for Typographical Error
  • 2 smelters for Location Correction
  • 1 smelter for Metal Correction
  • 29 smelters for Name Correction

The updated CMRT and standard smelter list is available on the CFSI website. The manufacturers need to consider these for the 2015 reporting.

Conclusion

The changes have been made to standardize the compliance for conflict minerals

in the market. Consequent to which the manufacturers can source clear and precise data pertaining to 3TG. An important thing to note is that even with the revision, CMRT continues to have smelters mentioned in the standard smelter list who are undergoing due diligence. The standard smelter list will be updated by the CFSI regularly to help companies achieve their conflict minerals compliance. These updates are not only important for compliance but also for the better understanding of the smelters and integrating data on a uniform platform.

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