If you’re tracking minerals due diligence, prepare for major updates. Recognizing a need to support companies’ reporting requirements under the EU Battery Regulation, the Responsible Minerals Initiative (RMI) has recently voted to expand the scope of the Extended Minerals Reporting Template (EMRT), which will impact how you collect and report data on minerals in your supply chain.
What is the Extended Minerals Reporting Template (EMRT)?
The EMRT is a free, industry-standard reporting template initially developed by the Responsible Minerals Initiative (RMI). It was formally launched on October 20, 2021, to assist reporters in identifying pinch points and collecting due diligence information in the cobalt and mica supply chains.
The EMRT is a critical part of due diligence in supply chains, especially for companies that are committed to ethical sourcing and need a reliable way to report on mineral origins.
What’s Changing?
The RMI plans to release the expanded EMRT, named EMRT 2.0, in April 2025. Under the expanded scope, the EMRT will now include copper, natural graphite, lithium, and nickel – all minerals that fall under the due diligence obligations of the EU Batteries Regulation. This means that reporters will now need to start collecting and transmitting data related to these additional minerals.
EMRT 2.0 will also include an optional mine-level facility tab, as offered with the AMRT 1.2 file. With the expanded EMRT scope, the RMI will be able to identify new potential Responsible Minerals Assurance Process (RMAP) assessment participants and support supply chain assurance.
What this Means for Reporters
The inclusion of new substances in the EMRT means that your program requires expansion to address these additions. New suppliers may need to be included, and existing ones could find themselves juggling multiple due diligence requests.
Moreover, with increasing due diligence obligations on the horizon, such as the EU Corporate Sustainability Reporting Directive (CSRD) and the Corporate Sustainability Due Diligence Directive (CS3D), expanding templates aren’t the only forces driving scope expansion for your program. The CS3D and CSRD are set to accelerate this trend, requiring due diligence on all relevant commodities you source from your supply chain. The scope will only grow, so being proactive now will save you headaches later.
Where to Submit the Extended Minerals Reporting Template (EMRT)
Companies required to complete the EMRT will generally submit it as part of their due diligence and regulatory compliance procedures. While no single database exists for these submissions, businesses are encouraged to maintain robust records for review by regulatory authorities, partners, and stakeholders.
The EMRT is intended for internal company use, facilitating supply chain transparency and compliance. However, companies may need to make specific declarations or reports available to national or EU-level regulatory bodies upon request. It also serves as a critical resource for corporate sustainability reports and stakeholder disclosures.
Steps You Should Take
There are a few steps you can take now to prepare for the EMRT 2.0:
- Adjust your data collection to see which suppliers are now in the scope of requirements and which clients will be interested in this information.
- Start conversations with your suppliers about these changes. The earlier they know what’s coming, the more prepared they’ll be.
- Keep an eye on upcoming regulations like the CSRD and CS3D. Knowledge is power, and staying informed will help you adapt quickly.
- Use this time to strengthen your relationships with suppliers. A collaborative approach will make future due diligence processes smoother for everyone involved.
Get Support
The upcoming expansion of the EMRT signals a significant shift for companies engaged in mineral due diligence. As regulatory demands intensify, especially with the EU Battery Regulation and forthcoming directives like the CSRD and CS3D, companies must proactively adapt their supply chain reporting processes to meet broader and deeper transparency requirements. If you need assistance with minerals reporting, contact our team at [email protected]. Our experienced team can help you navigate your reporting requirements and develop a roadmap for continued compliance.
