Beyond 3TG: Why Cobalt, Mica, and Other Extended Minerals Now Demand Real Due Diligence
Beyond 3TG: Why Cobalt, Mica, and Other Extended Minerals Now Demand Real Due Diligence
For years, many companies treated responsible minerals compliance as a 3TG exercise.
They built a conflict minerals process around tin, tungsten, tantalum, and gold, sent out CMRTs once a year, chased supplier responses, and called it a day. That approach is getting old fast. The more serious question now is not whether a company has a 3TG program. It is whether that company can manage responsible sourcing risk across a broader set of minerals that sit in batteries, electronics, coatings, industrial materials, and other high-risk supply chains.
That is where cobalt and mica moved into the spotlight first. And now the scope is widening again.
The Responsible Minerals Initiative’s Extended Minerals Reporting Template was originally built for cobalt and mica supply chains. With EMRT 2.0, the scope expanded to include cobalt, copper, natural graphite, lithium, natural mica, and nickel. That is not just a template update. It is a practical sign that industry expectations are moving beyond a narrow 3TG lens.
The Real Shift Is Bigger Than One Mineral List
A lot of companies are still asking the wrong question.
They ask whether cobalt or mica is now “regulated like 3TG.” That is too simplistic. The better question is whether responsible sourcing expectations, customer demands, and due diligence frameworks now require visibility into a broader set of minerals and deeper supply-chain risks. The answer is yes. The OECD Due Diligence Guidance already makes clear that its framework is a basis for responsible supply chain management of all minerals from conflict-affected and high-risk areas, not just the original 3TG set.
That matters because many businesses still treat extended minerals as a future issue. It is not. The due diligence expectation is already here. The reporting infrastructure is catching up to it.
Why Cobalt and Mica Became Early Flashpoints
Cobalt and mica were never random additions.
They are visible because they sit in supply chains that have drawn sustained scrutiny around child labor, hazardous working conditions, artisanal mining risk, and weak upstream traceability. The OECD framework is built for exactly this kind of problem: minerals sourced from conflict-affected and high-risk areas where the risk is not just where a company buys, but what is happening further upstream in extraction, trade, handling, and processing.
That is what trips companies up. A direct supplier saying “we do not source from Congo” does not settle the question. Risk can sit at the smelter, refiner, processor, trader, or sub-tier level. If your due diligence never gets past tier one, you do not have much due diligence. You have supplier optimism.
What Changed Practically in 2025 and 2026
The cleanest factual development is not that every regulator suddenly rewrote the mineral rulebook. It is that reporting expectations and due diligence tools got broader.
RMI’s EMRT now covers cobalt, copper, natural graphite, lithium, natural mica, and nickel supply chains. RMI also distinguishes between CMRT for 3TG, EMRT for those extended minerals, and AMRT for other minerals outside those sets. That split matters because it shows the market is building more structured reporting lanes for minerals that used to be handled informally or not at all.
At the same time, the EU’s corporate sustainability due diligence framework reinforces the broader direction of travel. The directive is not mineral-specific, but it does require in-scope companies to identify and address adverse human rights and environmental impacts across their chains of activities. That kind of framework increases pressure on companies to understand where mineral-linked risks sit in practice, even when the law does not name cobalt or mica on the front page.
Where Companies Still Get This Wrong
The first mistake is assuming extended minerals only matter if the company buys raw minerals directly.
That is lazy thinking. Most downstream manufacturers and brands do not buy ore or concentrate. They buy components, assemblies, chemicals, coatings, or finished goods. The risk still travels with the product, and so does the due diligence burden. The OECD guidance is explicit that different actors in the supply chain have different roles, but all are expected to build management systems, identify and assess risk, respond to risk, support independent audit of smelter or refiner due diligence where appropriate, and report annually.
The second mistake is treating EMRT as just another questionnaire.
It is not just a spreadsheet nuisance. It is a mechanism for collecting smelter or processor information, policy data, and due diligence information across minerals that are becoming strategically important in electronics, batteries, and industrial supply chains. If you send it out without having a sourcing policy, escalation path, and data-review logic behind it, you will collect noise.
The third mistake is assuming the compliance problem is about geography alone.
Conflict-affected and high-risk areas are not a synonym for one country. The OECD framework is global in scope and risk-based in design. Companies that reduce the issue to “we do not source from X country” usually miss the real exposure.
Why This Matters Commercially
The lazy version of this story says extended minerals matter because customers care. That is true but shallow.
The stronger point is that broader mineral due diligence creates operational consequences. It changes what customers ask suppliers to disclose. It changes how OEMs assess sourcing risk. It changes how companies evaluate smelter lists, supplier responsiveness, and remediation timelines. It also changes which businesses look credible when large buyers start asking for more than a standard 3TG declaration.
This is where weak programs start to break. Not in public statements, but in execution. Supplier response rates drop. Smelter data comes back incomplete. Teams realize they have no policy language for cobalt or mica. Procurement thinks the issue belongs to compliance. Compliance thinks procurement owns the supplier relationship. Nothing moves until a customer deadline turns it into a fire drill.
That is not a reporting problem. That is a management problem.
What Real Extended Minerals Control Looks Like
A serious extended minerals program starts by dropping the fiction that 3TG and “everything else” can be handled the same way forever.
Companies need a policy that reflects broader mineral due diligence expectations. They need a clear owner for supplier outreach. They need a process for reviewing smelter, refiner, and processor data instead of just storing template responses. And they need to understand which minerals are already inside the reporting perimeter. For EMRT today, that means cobalt, copper, natural graphite, lithium, natural mica, and nickel.
They also need to get realistic about leverage. The OECD guidance does not assume companies can solve upstream risk instantly. It expects them to build management systems, use leverage where they have it, support mitigation, and make sourcing decisions with risk in view. That is a much more serious standard than collecting a declaration and hoping nobody asks follow-up questions.
The 3TG-Only Era Is Losing Ground
The market is not abandoning 3TG. It is moving past the idea that 3TG alone defines responsible minerals work.
That is the real shift.
Companies that still run their mineral due diligence program as a narrow Dodd-Frank routine are going to look increasingly outdated. Companies that broaden their controls now will be in a better position to answer customer demands, align with OECD-style risk-based due diligence, and manage the reporting burden that comes with wider mineral scrutiny.
The hard part is not knowing that cobalt and mica matter. The hard part is building a system that proves you know what to do about them.
