Conflict Minerals / 3TG Due Diligence Pages on Changzhou Manufacturer Websites: How Should They Be Accepted?

Direct answer: The EU Conflict Minerals Regulation (Regulation (EU) 2017/821) mainly regulates EU importers: when they import tin, tantalum, tungsten or gold (3TG) ores, concentrates or metals into the EU above the Annex I annual thresholds, they must carry out supply-chain due diligence under the OECD five-step framework and report annually. Most Chinese manufacturers are downstream and are not directly obligated; however, EU customers/brands pass requirements down through contracts, questionnaires and CMRT/EMRT, asking whether products contain 3TG, who the smelters/refiners are, how risks are managed and where the evidence is. On 16 October 2025 the European Commission recognised RMI's RMAP as "fully aligned" with the regulation for the first time, so EU importers can rely on it to demonstrate due diligence; but this does not make downstream suppliers automatically compliant, nor does it make a product "conflict-free". A conflict-minerals page should turn role/scope, 3TG material mapping, the five steps, CMRT/EMRT, smelters/RMAP, risk/CAHRA, customer questionnaires, contractual flow-down and evidence into a reviewable checklist—not just the sentence "we are conflict-free".

This guide is for electronics/electrical, automotive, medical device, equipment, hardware/tools, connector/harness, semiconductor and export manufacturers in Changzhou and nearby areas. It explains how to write and accept a conflict minerals/3TG due diligence page. Information is current to 2026-11-05. It is a review of public rules and project practice, not legal, mineral due diligence, audit or compliance advice; the specific scope, thresholds, duties, reporting and customer requirements depend on the regulation, European Commission guidance, Member State law, the customer contract and the latest RMI templates.

How does the conflict-minerals page relate to RoHS/REACH, supplier code, forced labour and battery pages?

The RoHS/REACH material compliance page answers substance restrictions, SVHC, SCIP and testing/declarations; the supplier code of conduct page answers labour/environment/business-ethics principles; the forced labour page answers whether a product is made with forced labour and how to investigate/remediate; the EU Battery Regulation page answers separate due diligence for cobalt, natural graphite, lithium and nickel; the conflict-minerals page only answers 3TG origin, smelters/refiners, risk and customer questionnaires. They can link to each other but cannot replace each other.

Common breakpoints: treating a RoHS test report as conflict-minerals evidence; treating one line in the supplier code ("supports 3TG due diligence") as completed; mixing battery cobalt/lithium due diligence with 3TG; using an ESG report as a questionnaire answer; checking only tier-1 suppliers and not knowing the smelter/refiner; writing "conflict-free" on the website without CMRT, a smelter list and a risk process. A page that states the boundaries gives procurement, quality, legal, sales and the website team one playbook.

This page map is editorial; conflict-minerals duties follow Regulation (EU) 2017/821, European Commission guidance and the customer contract.

Which regulations/market requirements ask for 3TG data?

At least five: (1) EU 2017/821 directly regulates EU importers of 3TG ores/concentrates/metals above Annex I thresholds, applies from 1 January 2021, and requires a supply-chain policy/management system, risk identification and response, third-party audit and annual reporting; (2) US Dodd-Frank Section 1502 (2010) mainly targets US-listed companies' 3TG due diligence and disclosure, passed down the supply chain through questionnaires; (3) EU customers/brands/industry associations ask for CMRT/EMRT, smelter lists, corrective action and contract clauses; (4) the China Chamber of Commerce of Metals, Minerals & Chemicals Importers & Exporters (CCCMC) has developed responsible mineral supply-chain due diligence guidelines aligned with the OECD framework—an industry guideline, not a generally mandatory law for all companies; (5) the EU Battery Regulation sets separate due diligence for cobalt, natural graphite, lithium and nickel. Do not merge them into one "EU conflict minerals certification".

Acceptance checks: product/market/customer; role as EU importer or upstream/downstream supplier; whether Annex I thresholds are exceeded; whether the customer wants CMRT or EMRT; whether the battery regulation applies; the exact contract/questionnaire version and deadline. Common gaps: assuming a Chinese factory is directly subject to EU 2017/821; treating US SEC rules as Chinese law; treating a customer questionnaire as law; treating battery cobalt/lithium as 3TG; preparing one "universal statement".

Subjects/scope are editorial; EU duties follow Articles 1–2, Annex I and the European Commission pages; US/China/customer requirements follow their own rules and contracts.

What is 3TG, and where does it appear in products?

3TG means only four: tin (Sn), tantalum (Ta), tungsten (W) and gold (Au). Typical uses: tin in solder, tin plating, bronze/brass and some stabilisers; tantalum in capacitors, alloys and chemical equipment; tungsten in carbide tools/dies, wear parts, contacts and weights; gold in connectors/contacts, bonding wire, plating and electronic components. Whether a product "contains 3TG" depends on the BOM, material certificates, supplier declarations and actual processes—do not guess by industry. Cobalt, lithium, natural graphite, nickel, mica and copper are not 3TG; if a customer asks for them, use EMRT, the Battery Regulation or a specific questionnaire—do not squeeze them into CMRT.

Acceptance checks: bill of materials; homogeneous materials/components; supplier tiers; whether smelters/refiners are traceable; recycled content; whether the customer wants a product-level or company-level declaration. Common gaps: writing only "electronics contain tin"; treating "contains gold" as jewellery/plating in one line; putting cobalt/lithium into 3TG; no BOM mapping; submitting blank when a supplier says "unknown".

Uses are editorial examples; specific materials, grades, content and supplier tiers follow the BOM, material certificates and customer requirements.

How should role and scope be determined?

Ask four questions: (1) Do you import 3TG ores, concentrates or metals into the EU? (2) Does the annual import volume exceed the Annex I threshold for the relevant CN code? (3) Are you upstream (mine, trader, smelter/refiner) or downstream (metal converted into parts/finished products)? (4) Does the customer/market/contract require CMRT/EMRT or a product-level declaration? EU 2017/821's direct obligations fall mainly on EU importers; downstream companies "beyond the metal stage" are not directly in scope, but customer contracts and brand requirements flow down. Most Chinese manufacturers are downstream suppliers; the correct wording is "support customers/EU importers with 3TG data and evidence", not "we are directly subject to/compliant with 2017/821".

Thresholds must be checked per CN code in Annex I—not a flat "100 tonnes". Annex I has been amended (e.g., 2020/1588 added thresholds for tantalum/niobium ores, gold ores, tin oxides, tantalates and tantalum carbides), and different minerals/metals/codes have different thresholds. Whether the threshold is exceeded, whether all imports in the same year are covered and how recycled metals are treated should follow the consolidated regulation and competent-authority interpretation. Get the scope wrong and the CMRT, audit and report will all be wrong.

Scope determination is an editorial method; thresholds/scope follow Article 1, Annex I, amendments such as 2020/1588 and European Commission interpretation.

How should CMRT, EMRT and AMRT be completed?

CMRT (Conflict Minerals Reporting Template) is RMI's free 3TG questionnaire, used to pass information from downstream up to "before the smelter/refiner", covering company/product scope, whether 3TG is present, smelter/refiner lists, country of origin and due diligence questions. EMRT (Extended Minerals Reporting Template) covers minerals beyond 3TG (the current version covers cobalt, copper, natural graphite, lithium, mica and nickel, subject to the current RMI template), and AMRT covers other minerals. Templates are updated annually; on 17 April 2026 RMI released functional CMRT/EMRT updates, and on 30 October 2026 it released versions without logos/branding (functionally identical). Use the latest version, state company-level vs product-level, the reporting period and how "unknown" items will be handled; do not use old email attachments or disclose a customer's proprietary questionnaire.

Acceptance checks: template version/release date; company-level or product-level; products/period covered; whether 3TG is present; smelter list; number of unknowns; evidence attachments; customer acceptance. Common gaps: using a 2020 template; answering only "Yes/No" without smelters; leaving "unknown" blank; mixing product-level and company-level; publishing the customer questionnaire; inventing coverage when a supplier does not reply.

Template scope/version follow the current RMI MRT Introduction; customers may require a specific version or their own questionnaire.

How should smelters/refiners and RMAP be described?

The key "pinch point" in conflict-minerals due diligence is the smelter/refiner (SOR): ore is concentrated and processed there, making upstream tracing difficult. RMI's RMAP (Responsible Minerals Assurance Process) uses independent third-party assessment of a smelter/refiner's management system and sourcing practices; its standards align with the OECD Guidance, EU 2017/821 and US Dodd-Frank; assessments are valid for one or three years and results appear in RMI's public facilities lists by metal/status. On 16 October 2025 the European Commission adopted Implementing Decision (EU) 2025/2071, recognising RMAP as "fully aligned" with the regulation for the first time; EU importers can rely on it to demonstrate due diligence, and it is a step toward a "list of global responsible smelters and refiners". Note: RMAP assesses facility systems—it is not material validation, nor a product/company "conflict-free certification"; downstream companies still need their own scope, data, risk and customer questionnaires.

Acceptance checks: smelter/refiner name, country, metal, RMAP status/assessment date; whether it is on the customer's accepted list; unknowns/non-conformances; alternatives/remediation; whether evidence traces back to CMRT. Common gaps: writing "RMAP conformant" as "product conflict-free"; using an outdated list; writing only "suppliers are required to comply"; not knowing the smelter; treating a trader as a smelter; treating RMAP as ISO certification.

RMAP rules/status follow RMI Assessments and the European Commission news of 17 October 2025; customer acceptance follows the contract.

How should the OECD five-step framework be implemented?

EU 2017/821 requires EU importers to follow the five-step framework in the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: (1) establish strong company management systems (policy, responsibility, supplier onboarding, records, grievance); (2) identify and assess supply-chain risks (3TG, origin, smelter, CAHRA, supplier); (3) design and implement a response (continue, suspend, terminate, mitigate, remediate); (4) have supply-chain due diligence independently audited by a third party (recognised schemes such as RMAP can help); (5) report annually on supply-chain due diligence. Downstream suppliers, even if not directly in scope, can prepare customer evidence using the same five steps; do not stop at "the supplier signed a statement".

Acceptance checks: policy approved/public; owner/cross-functional team; supplier onboarding and contracts; risk register; response records; audit/assessment evidence; annual report/customer update. Common gaps: a one-line policy; no risk tiering; identified risks not handled; customer audit treated as third-party audit; annual report copied from a template; no grievance/remediation mechanism.

The five steps follow the OECD Guidance and the European Commission "regulation explained" page; the audit/report format follows the regulation, customer and recognised scheme.

How should risk and CAHRA be tiered?

CAHRA (conflict-affected and high-risk areas) are areas with natural-resource wealth and armed conflict/fragile post-conflict conditions, weak governance or systematic human-rights abuses. The European Commission is establishing and regularly updating an indicative, non-exhaustive CAHRA list (the CAHRA list contract was awarded in December 2025; in June 2026 the Commission also launched a review of the regulation). Not being on the list does not mean no risk. Risk tiering should at least consider: mineral/metal; country/region of origin; smelter/refiner; supplier tier/transparency; conflict, forced labour, corruption, money laundering, sanctions; transaction/transport route; customer/market sensitivity. High-risk items need due diligence, mitigation and remediation, and if necessary suspension/termination—not just a country risk map.

Acceptance checks: risk matrix; CAHRA source/date; supplier/smelter risk; response to high-risk items; management/board awareness; review cycle. Common gaps: looking only at country names; treating "not CAHRA" as zero risk; not updating; no high-risk response; no decision record; treating risk tiering as a compliance conclusion.

CAHRA lists and risk methods are editorial; specific determinations follow European Commission/international public information and customer requirements, not a risk/legal conclusion.

What will customer questionnaires ask?

Common: company/product/period scope; whether 3TG is present; which CMRT/EMRT version is used; company-level or product-level; smelter/refiner list; country of origin; RMAP status; policy/five steps; high-risk items/corrective action; annual update; grievance channel; contract/flow-down; whether cobalt/lithium/graphite and other extended minerals are involved. Answers must be truthful, traceable and versioned; for "unknown", state the reason, plan and deadline—do not answer "Yes" or "No" to everything. Customers may require the raw CMRT, smelter list, corrective plan, audit summary and an NDA; do not publish customer-specific questionnaires on the website.

Acceptance checks: questionnaire library/version; answer-to-evidence mapping; unknown list; corrective plan; customer acceptance record; update cycle. Common gaps: inconsistent answers across customers; old version; writing "unknown" as "none"; no evidence; questionnaire answers inconsistent with CMRT; no update after expiry.

Questionnaire items are editorial; specifics follow the customer/brand questionnaire, contract and RMI templates.

How should contracts and flow-down be written?

Contracts can include: supplier commitment to the 3TG policy; provision of the latest CMRT/EMRT and smelter/refiner list as required; advance notice of origin/source changes; corrective plan and deadline for high-risk/unknown items; audit rights or audit evidence for the customer/its assessor; flow-down to subcontractors/tier-2 suppliers; data confidentiality and public-disclosure boundaries; suspension/termination/indemnity for breach; annual review. As a supplier, distinguish "what we can commit" from "the customer's/EU importer's legal obligations"; do not promise the customer's 2017/821 compliance, and do not treat a signed supplier statement as completed due diligence.

Acceptance checks: clause coverage; CMRT/EMRT delivery deadline; change notification; audit rights; remediation/termination; flow-down; confidentiality; version. Common gaps: one line "conflict-free"; no deadline; not passing to tier-2; refusing audits; not terminating after a finding; attaching questionnaire answers as a contract annex but never updating them.

Contract clauses are editorial; specifics follow the customer contract, applicable law and legal advice.

How should the website conflict-minerals page be written?

A public page should include: (1) scope/role (EU importer/upstream/downstream supplier/customer requirement); (2) 3TG policy and management system; (3) product/material mapping (which products may contain 3TG); (4) OECD five steps and annual update; (5) CMRT/EMRT data scope and version; (6) smelter/refiner list and RMAP status (the part that can be public); (7) risk/CAHRA/grievance/remediation; (8) customer questionnaire/evidence request channel; (9) contract/flow-down; (10) contact/version/update date. Write verifiably: state "we have a policy/process/data/evidence", not "100% conflict-free/certified/fully compliant".

Separate "public information" from "customer/sensitive documents": CMRT details, customer-specific questionnaires, the full smelter list, contracts and audit reports are provided per permission/NDA; the public page gives scope, method, evidence types and a contact. If you are only a downstream supplier, state that you support EU customers/importers with 3TG data and evidence—do not declare the customer compliant. The English page should match export markets and use consistent terms (3TG, CMRT, smelter/refiner, CAHRA, due diligence).

This page structure is editorial; external claims must be truthful and verifiable, per the regulation, customer contract and company policy.

What must not be written?

High-risk claims: "100% conflict-free/absolutely clean" (cannot be guaranteed; RMAP is not a product guarantee); "RMAP-certified company/product" (RMAP assesses smelter/refiner facilities, not company/product certification); "we comply with EU 2017/821" (if you are not an EU importer, the direct duty is not yours; write "support customers/importers"); "CMRT completed = compliant" (the template is only a questionnaire); "not on the CAHRA list = no risk" (the list is indicative and non-exhaustive); "cobalt/lithium/graphite are 3TG" (they are not); "all products are in scope" (depends on 3TG/customer/market); "customer compliance = our compliance" (separate duties); "the supplier signed a statement, so due diligence is done" (data, risk, audit/remediation are still needed). These are inaccurate or misstate responsibility.

Safer wording: "As a downstream supplier, we provide 3TG origin, CMRT/EMRT, smelter/refiner and corrective information as required by customers/EU importers; we maintain a policy, risk process, audit and annual update under the OECD five steps; the specific compliance conclusion follows the regulation, customer contract and competent authority." External promotion must also comply with advertising/fair-competition law; customer/supplier/smelter data needs authorisation/redaction.

These red lines are editorial; whether a claim is false advertising/non-compliant is determined by regulators and the contract, and this is not legal advice.

Go-live acceptance checklist

Ten checks: scope/role, 3TG material mapping, policy/management system, CMRT/EMRT data, smelters/RMAP, risk/CAHRA, remediation/grievance, customer questionnaire/evidence, contract/flow-down, page wording/version. Each needs an owner, evidence and review date. The pass condition is not "the page says conflict minerals", but that a customer/EU importer can see your role, data, risk process and evidence.

Before go-live, run one real customer questionnaire through: scope → BOM → CMRT → smelters → risk → remediation → contract → page wording. Any step that fails is a gap in the page or the process. If data is missing, write "unknown + plan"; do not fill everything with "conflict-free".

This checklist is editorial; specific compliance requirements follow the regulation, customer contract and competent authority.

Who should read this, who should not, and what decisions does it support?

It suits procurement, quality, legal, sales and website teams at electronics/electrical, automotive, medical device, equipment, hardware/tools, connector/harness, semiconductor, battery and export manufacturers in Changzhou and nearby areas; also companies supplying EU customers/brands and receiving CMRT/EMRT or conflict-minerals questionnaires. It does not suit businesses that do not sell to EU/US customers, have products with no 3TG, or want one page to replace legal/mineral due diligence/audit advice.

Read it if an EU customer asks for CMRT/EMRT; your products contain tin/tantalum/tungsten/gold; you need to explain smelters/RMAP; you are building or revising a conflict-minerals page; or you need to separate 3TG, RoHS, the Battery Regulation, forced labour and ESG. Skip it if you treat CMRT as compliance proof, write "100% conflict-free", or assume a Chinese factory is directly subject to 2017/821. It supports self-review of scope, BOM mapping, the five steps, CMRT, smelters, risk, contracts and page wording.

FAQ

Does EU 2017/821 directly apply to Chinese manufacturers?

Mostly no. The direct obligations target EU importers of 3TG ores/concentrates/metals above Annex I thresholds; most Chinese manufacturers are downstream suppliers and receive requirements through customer contracts, CMRT/EMRT and brand requirements. If you are established in the EU and import 3TG, or your role is an EU importer, it may apply directly; confirm with legal/compliance.

What are the four 3TG minerals? Are cobalt and lithium included?

3TG means only tin, tantalum, tungsten and gold. Cobalt, lithium, natural graphite, nickel, mica and copper are not 3TG; customers usually request EMRT, the Battery Regulation or a specific questionnaire for those. Putting cobalt/lithium into CMRT answers the wrong scope.

Does completing CMRT mean compliance?

No. CMRT is RMI's standard questionnaire for passing 3TG, origin and smelter/refiner information through the supply chain; it does not prove a product is "conflict-free" and does not replace policy, risk identification, response, third-party audit and annual reporting. Customers also look at data completeness, unknown-item plans and corrective action.

What is RMAP? Can the "whitelist" be used directly?

RMAP is RMI's Responsible Minerals Assurance Process; independent third parties assess smelter/refiner systems and sourcing practices, with standards aligned with OECD, EU 2017/821 and Dodd-Frank. On 16 October 2025 the European Commission recognised it as fully aligned with the regulation for the first time. It is a facility-level assessment, not a product/company "conflict-free certification"; before use, check the metal, status, assessment date and the customer's accepted list.

What should we do when a customer asks for CMRT, a smelter list and a corrective plan?

First confirm the template/version, company-level or product-level, period and confidentiality requirements; then work through BOM → supplier → CMRT → smelter → risk → remediation. For unknown items, state the reason, plan and deadline truthfully; provide customer-specific questionnaires/full lists under an NDA, not on the public website.

Can the website say "conflict-free"?

Absolute "conflict-free/100% conflict-free" is not recommended. You can write "we conduct 3TG due diligence as required by customers/EU importers, providing CMRT/EMRT, smelter/RMAP status and corrective information; specifics follow the regulation, customer contract and competent authority". Absolute claims cannot be guaranteed and can be misleading.

One-sentence takeaway

A Changzhou manufacturer's conflict-minerals/3TG page is not about the words "conflict-free". It should turn scope/role, 3TG material mapping, the OECD five steps, CMRT/EMRT, smelters/RMAP, risk/CAHRA, customer questionnaires, contractual flow-down and evidence into a reviewable checklist—so a customer/EU importer can see your role, data, risk and remediation.

Method and limitations

This is a review of public rules and project practice, not an audit, certification or legal opinion on any company, product, mineral supply chain or compliance. No undisclosed customer, supplier, smelter or questionnaire data were used. Scope, five steps, risk tiering, questionnaire items and acceptance checklist are editorial suggestions, not legal, mineral due diligence or audit conclusions. Specific scope, thresholds, duties, reporting, penalties and customer requirements depend on the regulation, European Commission guidance, Member State law, the customer contract and the latest RMI templates.

Sources and scope

Information is current to 2026-11-05. The following are EU official/industry primary pages; their articles, thresholds, template versions and customer requirements control.

1. Regulation (EU) 2017/821 on supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas: EUR-Lex. Scope, Annex I thresholds, five steps, audit, reporting and competent authorities.
2. European Commission, Conflict Minerals Regulation: European Commission. Application from 1 January 2021, ReMIS, scheme recognition, the 16 October 2025 RMAP decision and latest review updates.
3. European Commission, The regulation explained: European Commission. 3TG, CAHRA, upstream/downstream, five steps, 600–1,000 EU importers and China's CCCMC guidelines.
4. European Commission, First supply chain due diligence scheme recognised under the Conflict Minerals Regulation (17 October 2025): European Commission. RMAP fully aligned with the regulation; importers can rely on it.
5. Responsible Minerals Initiative, MRT Introduction: RMI. CMRT/EMRT/AMRT templates, 17 April 2026 functional updates and 30 October 2026 unbranded versions.
6. Responsible Minerals Initiative, RMI Assessments / RMAP: RMI. Independent third-party assessment of smelters/refiners, standards aligned with OECD/EU 2017/821/Dodd-Frank, not material validation.