Conflict Minerals (3TG)

Tin, Tantalum, Tungsten, and Gold Due Diligence

Conflict minerals due diligence requires companies to determine whether tin, tantalum, tungsten, or gold (3TG) in their products originate from conflict-affected or high-risk areas. SEC disclosure rules, the EU Conflict Minerals Regulation, and OEM customer requirements make this a non-negotiable compliance obligation for manufacturers and suppliers across the electronics, automotive, aerospace, and industrial sectors.

What you receive

CMRT Packages & Due Diligence Reports

We deliver complete conflict minerals documentation packages including validated CMRTs, smelter verification reports, RCOI summaries, and SEC-ready filing support.

Full CMRT collection, validation, and rollup across your supplier base
Smelter list deduplication and RMAP conformance verification
Supplier outreach campaigns with 85%+ response rates
Audit-ready documentation for SEC, customer, and regulatory submissions

CMRT compliance documentation prepared by The 3TGs

Who it applies to

SEC-reporting companies that use 3TG in their products, EU importers of 3TG minerals or metals above threshold volumes, and any manufacturer or supplier whose customers require CMRT reporting as part of their supply chain due diligence programs.

Key requirements

Conduct a Reasonable Country of Origin Inquiry (RCOI) to determine whether 3TG originates from covered countries
Collect and validate Conflict Minerals Reporting Templates (CMRTs) from suppliers
Identify smelters and refiners in the supply chain and verify their conformance status
File SEC Form SD and Conflict Minerals Report (for SEC registrants)
Maintain auditable records of due diligence activities and findings
Apply OECD Due Diligence Guidance for Responsible Supply Chains

Key frameworks and obligations

SEC Rule 13p-1: annual filing for companies where 3TG is necessary to product functionality
EU Regulation 2017/821: due diligence obligations for EU importers above volume thresholds
CMRT Version 6.x is the current standard template maintained by the RMI
RMI Responsible Minerals Assurance Process (RMAP) is the primary smelter audit program
OECD five-step framework is the globally recognized due diligence standard

Common compliance gaps

Low supplier response rates caused by unclear communications and inconsistent follow-up
Accepting CMRTs at face value without validating smelter lists or checking for duplicates
Using company-level declarations when product-level or division-level reporting is required
Not applying conservative declaration logic, resulting in overly optimistic compliance status
Treating conflict minerals as an annual exercise instead of a continuous program
Failing to maintain documentation sufficient for SEC audit or customer due diligence review

How The 3TGs helps

CMRT collection, validation, and rollup across your full supplier base
Smelter identification, deduplication, and RMAP conformance verification
Conservative declaration logic: declarations reflect worst-case reality, not supplier optimism
Multi-wave supplier outreach campaigns with structured escalation for non-responders
SEC Form SD and Conflict Minerals Report preparation support
Annual program cycle management: scoping, collection, analysis, reporting
Audit-ready documentation packages for customer and regulatory submissions

Need conflict minerals due diligence support? We run the full program from supplier outreach to board-ready reporting.

info@3tgs.org · +44 20 3996 3623