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Conflict Minerals: Automate 3TG Due Diligence

Conflict minerals regulations in both the US (Dodd-Frank Section 1502) and the EU (Regulation 2017/821) require companies to trace the sourcing of tin, tantalum, tungsten, and gold (3TG) through their supply chains, conduct due diligence, and file compliant disclosures. With supply chains spanning multiple tiers and continents, manual CMRT collection and verification is error-prone and resource-intensive.

Conflict minerals software automates the collection of Conflict Minerals Reporting Templates (CMRTs), conducts reasonable country of origin inquiries (RCOI), and generates compliant disclosures for SEC and EU filing.

The Conflict Minerals Challenge

Who Is Affected

Jurisdiction Affected Companies Requirement
US (Dodd-Frank) SEC filers that manufacture products containing 3TG RCOI + due diligence + annual Form SD filing
EU (Reg 2017/821) EU importers of 3TG minerals and metals (annual volume thresholds) OECD-aligned due diligence + annual report
Supply chain flow-down Any company supplying products to regulated entities CMRT submission upon request

What Are 3TG Minerals

Mineral Symbol Common Uses
Tin Sn Solders, electronics, food packaging
Tantalum Ta Capacitors, medical devices, aerospace alloys
Tungsten W Drill bits, cutting tools, automotive parts
Gold Au Connectors, bonding wire, electronics

Key Requirements

Requirement US (Dodd-Frank) EU (Reg 2017/821)
Scope Products containing 3TG 3TG ores, concentrates, and metals (smelter+)
RCOI Required — determine if minerals originated in DRC region Not separately defined (part of due diligence)
Due diligence OECD-aligned framework required OECD-aligned framework required
CMRT collection Standard industry practice Standard industry practice
Reporting Annual Form SD to SEC Annual supply chain report to national authority
Smelter audit RMAP certification accepted RMAP certification accepted

What Conflict Minerals Software Automates

1. CMRT Collection & Management

  • Automated CMRT distribution to suppliers
  • Multi-year statement management and version control
  • Data validation (format, completeness, consistency)
  • Supplier portal with self-service submission

2. Reasonable Country of Origin Inquiry

  • Smelter and refiner country-of-origin analysis
  • Country risk classification (DRC region vs. non-DRC)
  • Automated follow-up for incomplete responses

3. Due Diligence Workflow

  • OECD 5-step framework implementation
  • Smelter audit status tracking (RMAP, cross-recognition)
  • Supply chain tracing to mine level
  • Risk assessment and mitigation planning

4. Disclosure Generation

  • Form SD (US) and EU annual report generation
  • Public-facing disclosure web pages
  • Audit-ready evidence collection

Top Conflict Minerals Software Platforms (2026)

1. Sustalium — Multi-Regulation Supply Chain DD

Sustalium provides conflict minerals compliance alongside broader supply chain due diligence — covering 3TG, battery raw materials, and modern slavery in a single platform.

Key Features:

Feature Sustalium
CMRT collection and validation Supplier portal with automated distribution
RCOI workflow Smelter country-of-origin + risk classification
OECD-aligned due diligence 5-step framework with audit trail
Smelter audit tracking RMAP and cross-recognition status
Form SD framework Structured framework aligned to SEC format
EU annual report framework Structured framework aligned to EU Reg 2017/821
Battery raw materials DD Cobalt, lithium, nickel, graphite overlap
Modern slavery integration Combined reporting
Pricing €10 per document per month

Best for: Companies needing conflict minerals together with battery raw material due diligence and modern slavery reporting.

2. Source Intelligence — Dedicated 3TG Platform

Source Intelligence provides purpose-built conflict minerals compliance.

  • Automated CMRT collection and analysis
  • Smelter research and country-of-origin database
  • Form SD generation
  • Pricing: Custom (typically €5K-30K/year)

Best for: Companies with complex 3TG supply chains needing dedicated smelter research.

3. Assent — Supply Chain Compliance

Assent provides supply chain compliance management including conflict minerals.

  • CMRT management across product lines
  • RMAP audit tracking
  • Regulatory filing support
  • Pricing: Custom (typically €10K-40K/year)

Best for: Mid-market manufacturers with multi-framework supply chain compliance needs.

4. Transparency-One — Supply Chain Mapping

Transparency-One focuses on supply chain mapping and traceability.

  • Multi-tier supply chain mapping
  • CMRT collection at each tier
  • Risk heat mapping
  • Pricing: Custom (typically €15K-50K/year)

Best for: Companies prioritising end-to-end supply chain visibility.

Feature Comparison

Feature Sustalium Source Intelligence Assent Transparency-One
CMRT collection and validation ✅ ✅ ✅ ✅
RCOI workflow ✅ ✅ ✅ ✅
Smelter audit tracking (RMAP) ✅ ✅ ✅ ❌
OECD 5-step due diligence ✅ ✅ ✅ ❌
Form SD generation ✅ ✅ ✅ ❌
EU Reg 2017/821 reporting ✅ ❌ ✅ ❌
Battery raw materials DD ✅ ❌ ❌ ❌
Modern slavery reporting ✅ ❌ ✅ ❌
Multi-tier supply chain mapping ❌ ❌ ❌ ✅
Per-document pricing ✅ (€10/month) ❌ ❌ ❌
Starting price €10/month ~€5K/year ~€10K/year ~€15K/year

Last updated: July 2, 2026