3TG reporting requires manufacturers of industrial products to trace tin, tantalum, tungsten, and gold through every supply tier to the smelters and refiners that processed them, then file Form SD and a Conflict Minerals Report (CMR) under SEC Rule 13p-1 if any of those minerals are necessary to product functionality or production [S1][S4].
Four minerals are in scope: tin, tantalum, tungsten, and gold. SEC Rule 13p-1 limits the regulated upstream geography to the Democratic Republic of the Congo and adjoining countries, while the EU Conflict Minerals Regulation and the RMI's CMRT take a broader view, covering 3TG from any conflict-affected and high-risk area (CAHRA) [S1][S4][S5]. General Motors' 2022 CMR illustrates the scale: 2,764 first-tier supplier locations were surveyed, 90% returned completed CMRTs, and 343 SORs were identified, of which 22 were flagged as sourcing from a Covered Country [S1].
Which Industrial Products Trigger 3TG Reporting
Reporting is triggered when 3TG is "necessary to the functionality or production" of a manufactured product, a phrasing drawn directly from Section 1502 of the Dodd-Frank Act and codified in SEC Rule 13p-1 [S1]. Practically, that covers electronics with soldered components, automotive electronics, aerospace alloys, cutting tools, and most assemblies containing electrolytic capacitors or gold-plated contacts [S4]. Tungsten is used in cemented-carbide cutting tools and high-stress aerospace parts; tantalum is the dielectric in surface-mount capacitors found in industrial industrial camera modules, sensor hubs, and PLCs; tin anchors solder joints on every populated PCB; gold ensures reliable contact in connectors and relay surfaces [S4][S7].
The Automotive Industry Action Group (AIAG) and the Responsible Minerals Initiative (RMI) treat 3TG as a baseline, then extend to cobalt, mica, and additional minerals through the EMRT and AMRT [S2][S3][S7]. A product does not need to be made in the US to be in scope, and the CMRT cascade is voluntary under the EU regulation but remains the de facto data-exchange format across both jurisdictions [S2][S4][S5].
Regulatory Frameworks: Dodd-Frank vs. EU vs. Industry
US filers operate under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which drives the annual Form SD and Conflict Minerals Report cycle for SEC registrants; the CMR must describe the registrant's reasonable country of origin inquiry (RCOI) and the due-diligence measures taken [S1]. The EU Conflict Minerals Regulation imposes separate disclosure duties and extends the upstream scope from DRC-adjacent countries to any CAHRA [S4][S5]. The RMI's Conflict Minerals Reporting Template (CMRT) is the common data format used under both regimes, and the Extended Minerals Reporting Template (EMRT) plus the Additional Minerals Reporting Template (AMRT) cover cobalt/mica and the broader mineral set [S2][S3].
In practice the workflows line up as: identify first-tier suppliers that may ship 3TG-containing parts, cascade the CMRT through them, reconcile SOR lists against the RMI's conformant smelter list, run the RCOI, conduct due diligence, then file Form SD and, where required, the CMR [S1][S3][S8]. Sourcing platforms such as IntegrityNext, Z2Data, and iPoint fold CMRT collection into a broader product-compliance stack that also tracks REACH, RoHS, TSCA, cobalt, and mica, so a single part record can satisfy multiple regulatory queries at once [S3][S4][S5].
CMRT Data Exchange and the SOR Cascade
The Conflict Minerals Reporting Template is a free, RMI-maintained Excel-based template that captures smelter and refiner names, addresses, and country of origin for each 3TG metal; the latest version also lists RMI Responsible Minerals Assurance Process (RMAP) conformance status so buyers can flag non-conformant facilities [S2]. The CMRT is sent to direct suppliers, who are expected to cascade it down their own supply chain, so SOR data eventually surfaces from several tiers below the buying OEM [S1][S3][S8]. GM's 2022 disclosures show the result: 343 SORs identified across 2,764 supplier locations, with some suppliers reporting only at company-wide level rather than at part level, which limits the registrant's ability to confirm whether a flagged SOR is actually present in any given product [S1].
Key parameters and the data items that must be captured per SOR include the official Smelter ID from the RMI Smelter Reference List, the metal being processed, the smelter country, the source mine country (where known), and an RMAP audit status; for the EMRT and AMRT the same fields are extended to cobalt, mica, and the additional minerals list [S2][S3]. The 2022 GM filing, the AIAG guidance, and a Mercedes-Benz supply-chain statement all converge on the same template structure, which is why the RMI version is treated as the de facto cross-industry standard rather than a Dodd-Frank-only artefact [S1][S7][S10].
Comparison of 3TG Reporting Templates
Three RMI templates now cover the industrial minerals disclosure landscape. The CMRT addresses tin, tantalum, tungsten, and gold, and is the only template required for SEC Form SD filings under Rule 13p-1 [S1][S2]. The EMRT adds cobalt and mica, two minerals that sit alongside 3TG on most automotive and electronics customer surveys even though SEC rules do not yet mandate their disclosure [S3]. The AMRT covers additional minerals, including lithium, nickel, and rare earths, and is used for voluntary customer surveys and EU-driven due-diligence requests [S3].
Selection follows the question being asked. A buyer with a Dodd-Frank audit need uses the CMRT; an OEM chasing cobalt due-diligence declarations for batteries and superalloys adds the EMRT; a company preparing for EU Battery Regulation or extended customer sustainability surveys layers in the AMRT [S2][S3][S5]. All three are generated from the same supplier-declaration dataset inside compliance platforms such as Z2 Compliance Manager, so the marginal cost of adding cobalt or mica is largely data-collection time, not template maintenance [S3].
Industrial Use Cases: Where 3TG Reporting Bites Hardest
Electronics assembly is the highest-friction case. Tin-lead and lead-free solder, gold wire bonding, gold plating on connector fingers, and tantalum capacitors in nearly every digital module all generate CMRT line items, and a typical populated PCB may pull in 3TG from a dozen or more SORs spread across Asia, South America, and Africa [S1][S4]. Automotive electronics face the same pressure, and a vehicle's wiring harness, ECU connectors, and sensor modules can each trigger SOR-level questions that a tier-one supplier must answer before the OEM can sign its Form SD [S1][S4].
Cutting tools and wear parts introduce tungsten as tungsten carbide, while heat-resistant aerospace components pull in high-purity tungsten and gold alloys; medical devices, industrial machinery, and industrial coating baths round out the user base that sees 3TG in its BOM and must cascade the CMRT down through powder suppliers, blank suppliers, and finishers [S4]. Even products that look "non-electronic" on the surface often carry 3TG in the form of soldered sensors or gold-plated contacts, which is why most industrial compliance programs now keep 3TG as a permanent BOM attribute rather than a one-off survey [S1][S3][S4].
Failure Modes and Common Pitfalls
The four pitfalls that most often derail a 3TG program are: incomplete CMRT coverage, mismatched SOR lists, weak RCOI evidence, and outdated RMAP conformance data. GM's 90% response rate on 2,764 suppliers in 2022 is on the high end of what large OEMs see, and a 10-percentage-point gap on a similar base leaves a meaningful slice of the supply chain unverified [S1]. Companies that report only at company-wide level (as GM's filing explicitly flags) cannot link a flagged SOR to a specific part, which weakens the audit trail even when the SOR itself is correctly identified [S1][S3].
Data freshness is the second risk. RMAP conformance is reassessed on a rolling cycle, and a smelter that drops conformance between two reporting periods can change the diligence outcome of an entire CMR; the RMI maintains the live list, but downstream reporters must re-pull and re-cascade rather than reuse last year's spreadsheet [S2][S3]. Third, the EU's CAHRA scope catches SORs that the US Dodd-Frank view would exclude, so a US-only program can pass an SEC audit and still fail an EU customer survey if the broader geography is not layered in [S4][S5]. Finally, conflating HART, PROFIBUS, or Ethernet-APL signalling with mineral provenance is a category error; those are fieldbus protocols, not 3TG traceability tools, and the two compliance tracks must be kept separate even when the same part touches both [S1][S3].
Standards, Sourcing, and Verifiable Signals to Track
The authoritative standards are SEC Rule 13p-1 (the implementing rule under Section 1502 of the Dodd-Frank Act) for US filers, the EU Conflict Minerals Regulation (EU 2017/821) for EU importers, and the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas, which most RMI members cite as the underlying due-diligence reference [S1][S4][S5][S10]. The RMI's Responsible Minerals Assurance Process (RMAP) is the de facto conformance scheme for SORs, and an "RMAP conformant" or "active" flag on the Smelter Reference List is the shorthand used in customer surveys [S2].
Trackable signals for the next reporting cycle include: the RMI's annual Smelter Reference List refresh, which sets the universe of auditable SORs; any EU Omnibus-driven change to CSDDD thresholds that may indirectly re-weight CAHRA scope; and the cobalt/mica portion of the EMRT, which is expanding faster than 3TG as battery and coatings supply chains tighten [S3][S5]. For industrial teams that also work on adjacent specifications, conflict-minerals data increasingly sits next to REACH, RoHS, and industrial adhesive compliance inside the same part record, and the same dashboard that shows 3TG coverage can be cross-checked against NACE MR0175 material declarations or ISO 9001 quality attributes where they overlap on the same component [S3].
This topic is covered further in Cutting Battery Formation and Ageing Time: Practical Routes for 2026 Cell Lines.