[Home](/)/[Resources](/resources)/Conflict Minerals (3TG) Compliance GlobalSupply ChainRegulation guide # Conflict Minerals (3TG) Compliance for Electronics Manufacturers Conflict minerals — tin, tantalum, tungsten, and gold (3TG) — are present in virtually every electronic product containing circuit boards, capacitors, and connectors. SEC Rule 13p-1 requires US-listed companies to disclose and conduct due diligence on 3TG sourcing from the Democratic Republic of Congo and adjoining countries. Even for non-US-listed manufacturers, customers increasingly require conflict minerals reporting aligned to OECD Due Diligence Guidance, and European supply chain due diligence obligations are expanding. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fconflict-minerals-3tg-compliance) At a glance SEC filing deadline May 31 annually (Form SD) Minerals in scope Tin, Tantalum, Tungsten, Gold DRC focus region DRC + 9 adjoining countries Industry template CMRT (RMI) ## Where 3TG appear in electronics ### Tin (Sn) **Detail:** Found in solder joints, PCB surface plating, and tin-plated connector contacts. Primary ore source is cassiterite. Present in virtually every PCB assembly containing soldered components. ### Tantalum (Ta) **Detail:** Found in tantalum electrolytic capacitors, which appear in virtually every PCB. Primary ore source is coltan (columbite-tantalite). High-density capacitor applications make tantalum one of the most common 3TG minerals in electronics. ### Tungsten (W) **Detail:** Found in vibration motors (used in mobile phones and wearables), wear-resistant tool tips used in PCB drilling, and heavy metal alloy components. Primary ore source is wolframite. ### Gold (Au) **Detail:** Found in bonding wire connecting die to package, PCB surface finish (ENIG — Electroless Nickel Immersion Gold), and connector contact plating. Gold's high unit value makes it the highest-scrutiny mineral in conflict minerals audits. ## SEC Rule 13p-1 requirements for US-listed companies 01 Determine whether 3TG minerals are necessary to the functionality or production of your manufactured products. Products containing PCBs, capacitors, or connectors are almost certain to be in scope. 02 Conduct a Reasonable Country of Origin Inquiry (RCOI) to determine whether 3TG minerals may originate from the Democratic Republic of Congo (DRC) or any of the nine adjoining countries. 03 If DRC/adjoining country sourcing is reasonably possible based on the RCOI: perform OECD-aligned supply chain due diligence covering your supply chain down to smelter/refiner level. 04 File Form SD with the SEC annually by May 31, covering the preceding calendar year. Form SD must be filed regardless of whether DRC sourcing is confirmed — even a 'reasonably possible' finding triggers the filing obligation. 05 Include a Conflict Minerals Report (CMR) with Form SD if DRC/adjoining country sourcing is reasonably possible. The CMR describes the due diligence measures taken and the results. 06 Obtain an independent third-party audit of the CMR if products cannot be designated as 'DRC Conflict Free'. The audit scope and auditor qualifications are specified in SEC rules. 07 Publish the CMR on your company website. The CMR must remain publicly accessible and be linked from the SEC filing. ## OECD due diligence — the 5-step framework 01 Step 1 — Establish strong company management systems: adopt a company conflict minerals policy aligned to the OECD model supply chain policy, establish internal controls and a grievance mechanism for reporting sourcing concerns. 02 Step 2 — Identify and assess risks in the supply chain: map your supply chain to identify the smelters and refiners processing 3TG minerals in your products. Survey component suppliers using the CMRT to collect smelter data. 03 Step 3 — Design and implement a strategy to respond to identified risks: engage directly with smelters identified as sourcing from conflict-affected areas. Establish a timeline for RMAP conformance and suspend or terminate relationships with smelters that show no progress. 04 Step 4 — Carry out independent third-party audit of supply chain due diligence: third-party audits of smelters and refiners are conducted through the RMAP (Responsible Minerals Assurance Process). RMAP-conformant smelters are publicly listed by the RMI. 05 Step 5 — Report annually on supply chain due diligence: report publicly through Form SD/CMR (US-listed companies), annual sustainability/responsible sourcing report, or customer-facing CMRT responses. Annual reporting closes the OECD due diligence loop. ## RMAP and smelter certification ### RMAP — Responsible Minerals Assurance Process **Detail:** Industry initiative administered by the Responsible Minerals Initiative (RMI) that audits smelters and refiners against the RMAP standard. RMAP-conformant smelters are listed publicly on the RMI website. Using RMAP-conformant smelters is the primary mechanism for demonstrating responsible sourcing. ### CMRT — Conflict Minerals Reporting Template **Detail:** The industry-standard data collection template for gathering smelter and refiner information from supply chain tiers. Suppliers complete the CMRT and pass it up the supply chain. Always use the current RMI-published CMRT version — outdated template versions are not accepted by customers or in SEC filings. ### EMRT — Extended Minerals Reporting Template **Detail:** The equivalent of the CMRT for cobalt and mica — minerals not covered by SEC Rule 13p-1 but subject to increasing customer due diligence requirements. Hardware manufacturers with batteries or certain pigments in scope should consider EMRT collection alongside CMRT. ### EU Conflict Minerals Regulation (EU) 2017/821 **Detail:** A separate EU obligation for EU importers of tin, tantalum, tungsten, and gold from conflict-affected and high-risk areas. Unlike SEC Rule 13p-1, the EU regulation applies to importers rather than manufacturers, and uses a different risk-based framework. EU importers of 3TG must conduct OECD-aligned due diligence and file annual reports with their competent authority. ## Frequently asked questions ### Does conflict minerals compliance apply to hardware companies that are not US-listed? SEC Rule 13p-1 applies only to companies that file reports with the SEC under the Exchange Act — primarily US-listed public companies. However, even non-listed hardware manufacturers are increasingly required to provide conflict minerals data to their customers through CMRT responses. Additionally, EU Regulation 2017/821 applies to EU-based importers of 3TG regardless of listing status. Many hardware companies treat OECD-aligned due diligence as a baseline commercial requirement even absent a direct SEC obligation. ### How do we collect smelter data from a supply chain with hundreds of component suppliers? The standard approach is to issue CMRT requests to all direct (Tier 1) component suppliers, who in turn collect data from their suppliers. Most electronics suppliers are familiar with the CMRT process through RMI membership or customer requirements. Data aggregation tools from RMI and commercial conflict minerals management platforms can consolidate CMRT responses and identify gaps. Prioritise by spend and criticality — capacitors, connectors, and PCBs are the highest-priority categories for smelter data collection. ### What is the CMRT and who do we send it to? The Conflict Minerals Reporting Template (CMRT) is a standardised Excel-based form published by the Responsible Minerals Initiative. It collects data on whether a company's products contain 3TG, which smelters/refiners process those minerals, and whether those smelters are RMAP-conformant. You send the CMRT to your direct suppliers, requesting they complete it for the components they supply to you. As a manufacturer, you may also be asked to complete a CMRT by your own customers. The RMI publishes the current CMRT version at responsiblemineralsinitiative.org. ### How does EU Conflict Minerals Regulation differ from SEC Rule 13p-1? SEC Rule 13p-1 applies to US Exchange Act reporting companies and focuses on manufactured products containing 3TG. EU Regulation 2017/821 applies to EU importers of raw or semi-processed 3TG (ore, concentrates, smelter output) rather than finished product manufacturers — making it primarily relevant to smelters, refiners, and upstream importers rather than finished electronics manufacturers. Electronics manufacturers selling into the EU are not directly regulated under 2017/821 but their EU-based suppliers may be, and supply chain due diligence obligations indirectly cascade through customer requirements. **Disclaimer:** Educational resource only. Regulatory requirements change and this page does not constitute legal or compliance advice. Consult qualified legal counsel and a compliance specialist for SEC filing obligations. [ Map your product, free Every standard, document, and test that applies — free, no account required. Start mapping](/platform/new)[ Want an expert to handle your compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Related guides * [EU Supply Chain Due Diligence (CSDDD)The EU CSDDD (Directive 2024/1760) requires large companies to identify, prevent, and address adverse human rights and environm…](/guides/eu-supply-chain-due-diligence) * [Section 889 Banned ComponentsComplete guide to Section 889 NDAA compliance — the five prohibited manufacturers, Part A and Part B prohibitions, component-le…](/guides/section-889-banned-components) * [EU Digital Product PassportThe EU Digital Product Passport is a core element of the Ecodesign for Sustainable Products Regulation (ESPR).](/guides/eu-digital-product-passport) * [US Supply Chain SecurityComplete guide to US supply chain security.](/guides/us-supply-chain-security)