Conflict Minerals - Applicable reporting period

Hello everyone,

Question: When filling out the CMRT, what is the covered period ? Are we looking at the past (what was produced) or the future (what we are going to produce)?

This has always bothered me. Each year, I considered what I had produced in the last year. This year however, I realized that a supplier was problematic and my CMRT was refused by our customer. However, if I eliminate this supplier, my CMRT becomes acceptable. Do I have to submit a CMRT considering my intention to no longer use this provider?

Thanks in advance !

I look at it strictly as a point-in-time snapshot (i.e., the Effective Date) of your ongoing compliance. The customers perform their due diligence via periodic (typically annual) requests for updated CMRTs.

My understanding (belief?) is that you are obliged to inform the customer if your compliance status worsens from your last CMRT. But to me, if you are maintaining your compliance status by changing/dropping suppliers, then I see no reason to send them a new CMRT.

But, whether you need to submit a new CMRT to your customer depends on any agreements you have with them.