CMRT 6.6 Is Live: Here's What Changed and What You Need to Do Before Your Next Filing

The Responsible Minerals Initiative (RMI) released a new version of the Conflict Minerals Reporting Template on April 17, 2026. CMRT 6.6 is now the current standard for 3TG conflict minerals reporting, replacing CMRT 6.5 which had been in use since April 2025.

If your company collects or submits conflict minerals data, whether as a supplier responding to customer requests or as a manufacturer running a Reasonable Country of Origin Inquiry (RCOI) this update applies to you. Here's what changed, why it matters, and what you should do next.

What Is the CMRT, and Why Does It Get Updated?

The Conflict Minerals Reporting Template is the industry-standard tool for exchanging due diligence information on tin, tungsten, tantalum, and gold collectively known as 3TG across global supply chains. It was developed by RMI and is aligned with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Under Section 1502 of the U.S. Dodd-Frank Act, publicly traded manufacturers are required to conduct due diligence on whether their products contain 3TG sourced from conflict-affected regions, particularly the Democratic Republic of the Congo (DRC) and adjoining countries. The CMRT is the primary mechanism through which this data flows up the supply chain, from smelters and refiners all the way to the companies filing Form SD with the SEC.

RMI issues updates to the CMRT periodically typically once a year to keep smelter reference data current, address reported issues, and improve the template's functionality. CMRT 6.6 is the 30th version of this template and the 10th release within the version 6 series.

What Changed in CMRT 6.6

This release includes both structural and maintenance updates. Unlike CMRT 6.5, which was limited to a smelter list refresh, CMRT 6.6 introduces a meaningful change to how product-level information is captured.

New Fields in the Product List Tab

The most notable change in CMRT 6.6 is the addition of two new fields in the Product List:

• Requester Product Number
• Requester Product Name

These fields allow the party requesting the declaration typically a customer or manufacturer to pre-populate their own product identifiers directly in the template. This makes it significantly easier to match supplier declarations to specific products in your internal systems, reducing the manual reconciliation work that often follows bulk CMRT collection.

For suppliers, this means you may begin receiving CMRT requests that already include your customer's product reference numbers. Filling in those fields accurately is now part of a complete submission.

IPC-1755 Compatibility

All enhancements in CMRT 6.6 are designed to remain fully compatible with IPC-1755, the international data exchange standard that governs how conflict minerals information is structured and transmitted between supply chain partners. This is important for companies using compliance platforms, ERP integrations, or automated data pipelines, the update should not disrupt existing workflows.

Updated ISO Country and Region Names

CMRT 6.6 updates the ISO short names for countries, states, and provinces throughout the template. This is a standardization improvement that ensures geographic data is consistently formatted and machine-readable, reducing errors in smelter country-of-origin declarations.

Smelter Reference List and Standard Smelter List Refresh

As with every CMRT release, the Smelter Reference List and Standard Smelter List have been updated to reflect the latest data from RMI. These lists are the core reference for identifying whether a smelter or refiner has been validated through a recognized audit program, such as the Responsible Minerals Assurance Process (RMAP).

Using an outdated smelter list means your RCOI may reference smelters whose audit status has changed, either newly certified or removed. CMRT 6.6 reflects the most current validated data available.

Why Updating to CMRT 6.6 Matters for Suppliers

Your Customers Will Expect It

Companies conducting RCOIs for their SEC filings are increasingly requiring that suppliers submit the most recent version of the CMRT. Data received using older template versions may be flagged as out-of-date, triggering follow-up requests. Submitting on CMRT 6.6 signals that your due diligence process is current and well-maintained.

It Protects Your Customer's SEC Filing

Form SD filings submitted to the SEC will reflect the CMRT version used to collect supplier data. For manufacturers, using CMRT 6.6 for data collection after April 17, 2026 demonstrates active due diligence, a hallmark of a defensible RCOI. As a supplier, submitting the latest version supports your customers' ability to file accurately and on time.

Smelter Data Accuracy Matters for RCOI

If your declaration references smelters that are no longer on the validated Standard Smelter List, or misses newly certified facilities, it can create gaps in your customer's due diligence documentation. The updated smelter lists in CMRT 6.6 ensure the reference data underlying your declaration is current.

Product Traceability Is Increasing

The addition of Requester Product Number and Requester Product Name fields reflects a broader trend in conflict minerals reporting: regulators and customers are pushing for greater product-level specificity. The EU Conflict Minerals Regulation, battery due diligence requirements, and evolving ESG disclosure frameworks are all moving in this direction. CMRT 6.6 begins to align with that trajectory.

Sources: Responsible Minerals Initiative (RMI)

CMRT 6.6 and the Broader Regulatory Landscape

It is worth noting that the regulatory environment around conflict minerals is currently in flux in the United States. In 2025, there was public discussion within the SEC about the effectiveness and cost burden of the Dodd-Frank conflict minerals rule, with some commissioners raising questions about its continued enforcement.

However, the EU Conflict Minerals Regulation which covers importers of 3TG into the European Union, remains in full force. And regardless of enforcement posture, supply chain transparency expectations from customers, investors, and ESG frameworks continue to grow. Companies that maintain strong conflict minerals due diligence programs, built on current tools like CMRT 6.6, are better positioned for both regulatory compliance and commercial relationships.

Action Steps: What to Do Right Now

For suppliers receiving CMRT requests:

1. Download CMRT 6.6 from the RMI website and replace any older versions in your workflow.
2. Review the new Requester Product Number and Requester Product Name fields, be prepared to populate these when your customers include them.
3. Check your smelter entries against the updated Smelter Reference List to confirm all listed smelters remain validated.
4. Notify your internal team of the version change, especially anyone responsible for responding to customer compliance surveys.

For manufacturers collecting supplier data:

1. Update your CMRT template to version 6.6 immediately and communicate the change to your supply base.
2. Consider pre-populating the new product identifier fields in your outbound requests to streamline reconciliation.
3. Ensure your compliance platform or data management system supports CMRT 6.6, check with your software provider if unsure.
4. Set supplier submission deadlines that give enough lead time for your Form SD filing, accounting for any re-submissions needed due to the template update.

What's Coming Next

RMI has indicated that the next version of the CMRT is anticipated in Spring 2027. Alongside CMRT 6.6, RMI also released updated versions of two companion templates in April 2026: EMRT 2.11 covers cobalt, copper, graphite, lithium, mica, and nickel - a scope expanded from cobalt and mica in EMRT 2.0 (April 2025). EMRT 2.11 focuses on usability and data quality improvements rather than mineral scope expansion and AMRT 1.31 (for minerals outside CMRT and EMRT scope),with the next AMRT version expected in Fall 2026. If your products contain battery metals or other critical minerals beyond 3TG, those templates are equally relevant to your due diligence program.

How Regilient Can Help

Staying on top of template updates is one piece of a larger conflict minerals compliance program. Whether you're building out your RCOI process for the first time, improving supplier engagement, or aligning your due diligence documentation with SEC and EU requirements, Regilient's compliance experts can help you get there.

If you have questions about CMRT 6.6 or how it affects your reporting obligations, reach out to our team. We're happy to walk you through what the update means for your specific supply chain situation.

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