How to complete the Cobalt
Reporting Template
CRT Rev. 2.11
June 2020
Japan Electronics and Information Technology
Industries Association (JEITA)-Responsible Minerals Trade Working Group【Notice】
This document is published by the JEITA Responsible Minerals Trade Working Group.
We endeavour to ensure that our information on RMI templates for responsible mineral sourcing is as recent andaccurate as possible, but please be aware that this will not always be the case.

Table of Contents
1. Cobalt Supply Chain Survey
2. Outline of CRT Rev. 2.11 and Recent
Changes
3. How to Complete the CRT
3.1 Declaration Sheet
3.2 Smelter List Sheet
3.3 Product List Sheet
3.4 Checker Sheet
4. How to Use the RMI website
Where necessary, please refer to “How to Complete the CMRT.”

2/40

1. Cobalt Supply Chain Survey: Background
While there are no laws or regulations like the Dodd–Frank Act for cobalt, thissurvey arose from concerns over unsafe working conditions and child labour inartisanal cobalt mining.
This is an excerpt from the explanation on the RMI (Responsible Minerals
Initiative) website
http://www.responsiblemineralsinitiative.org/emerging-risks/cobalt/
The Democratic Republic of the Congo (DRC) is the world’s largest producer of cobalt andholds more than 50 percent of the global cobalt reserves. Cobalt is used in lithium-ion
batteries that form an integral part of electric automobiles, mobile phones and laptop
computers. Demand for cobalt is expected to rise significantly over the coming years.
Cobalt is extracted in mechanized and artisanal mining operations. Multiple reports havehighlighted concerns over social and environmental impacts of cobalt extraction,
including child labor and unsafe working conditions in artisanal cobalt mining.
The RMI added cobalt as a dedicated focus area in 2017. We work to create the enabling
conditions for companies to exercise due diligence over cobalt supply chains inaccordance with the OECD Due Diligence Guidance.

3/40

1. Cobalt Supply Chain Survey: CMRT and CRT
comparison
Item
CMRT Rev. 6.01
CRT Rev. 2.11
Background/law

DFA Section 1502

EU Conflict Mineral
Regulation

No compliancerequirement
Growing international
interest in human rights
issues, etc.

Issuance
date

Applied as ofAugust 2012

Applied as of January
2021

NA

Subject of US listed companies Companies importing
regulations
metals into the EU

NA

MetalscoveredCobalt3TG
Tantalum, Tin, Tungsten, Gold

Regions
covered

DRC and the nineadjoining countries

CAHRAs*1

CAHRAs*1

RiskscoveredSource of funds forarmed groupsOECD Annex II Risks*2

OECD Annex II Risks*2*1, *2 explained in later pages

4/40

1. Cobalt Supply Chain Survey: OECD Annex II
Risks
OECD Annex II Risks refer to the risks in Annex II in OECD Due Diligence
Guidance for Responsible Supply Chains of Minerals from Conflict-Affected
and High-Risk Areas.*1
OECD Annex II Risks:
1. Serious abuses associated with the extraction, transport or trade ofminerals (child labor, etc.)
2. Direct or indirect support to non-state armed groups
3. Public or private security forces
4. Bribery and fraudulent misrepresentation of the origin of minerals
5. Money laundering
6. Payment of taxes, fees and royalties due to governments*1 Available for download on the OECD website

http://www.oecd.org/corporate/mne/mining.htm
5/40

1. Cobalt Supply Chain Survey: CAHRAs
Conflict-Affected and High-Risk Areas (CAHRAs)
Conflict-affected and high-risk areas are identified by the presence of armed
conflict, widespread violence or other risks of harm to people. Armed conflictmay take a variety of forms, such as a conflict of international or
non-international character, which may involve two or more states, or may
consist of wars of liberation, or insurgencies, civil wars, etc. High-risk areas
may include areas of political instability or repression, institutional
weakness, insecurity, collapse of civil infrastructure and widespread
violence. Such areas are often characterised by widespread human rights
abuses and violations of national or international law.
The CAHRAs remain conceptual at this point, with the EU yet to specify
particular regions as of 25 May 2020. The RMI standard, however,stipulates that the CAHRAs shall include, at a minimum, the Covered
Countries under the Dodd-Frank Act.

6/40

1. Cobalt supply chain survey: Cobalt smelter
definition
The RMI defines a cobalt smelter/refiner as “an entity that processes cobalt concentrates,intermediates or recycled feed and produces a cobalt product for direct use in adownstream manufacturing process.” Downstream manufacturers therefore need to
identify smelters at all these stages of the supply chain. However, because crude refiners
close to mines that refine metals from ore have recently begun receiving RMAP*1
assessments, they are beginning to appear on the Active Smelter list, etc.
(The cobalt industry and RMI use “smelter” and “refiner” interchangeably.)

Cobalt intermediates: Partially refined hydroxides, carbonates, and metals, etc.
Cobalt recycled feed: Industrial scrap and scrap from consumer goods scrap, etc.
Cobalt products: Electrical cobalt, cobalt sulfate, cobalt briquettes, cobalt powder, etc.
Cobalt concentrates andintermediates

Ore

Mine

Cobalt refiner(Crude refiner)
In DRC, Indonesia, etc.

Cobalt productCobaltsmelter/refiner

Recycled
feed

Downstream
company

In China, etc.

*1 RMAP is the RMI’s Responsible Minerals Assurance Process.

7/40

1. Cobalt supply chain survey: RMI SSN Status
This refers to the number of smelters recognized as Standard Smelter
Names by the RMI as of 13 May 2020 and their conformant status. The
list does not cover all smelters worldwide.

Cobalt

Co

SSN total: 55 smelters (of which 11 are crude refiners
Conformant: 5 (9%)
Active: 22 (of which 3 are crude refiners)
There are 5 conformant smelters, representing 9% of the total.
There are 22 active smelters (scheduled for assessment)of which 3 are
crude refiners.
Assessments are running behind schedule because of COVID 19.
8/40

2. Outline of CRT Rev. 2.11: Structure
The CRT comprises an Excel file with 8 sheets:

Revision, Instruction, Definitions, Declaration, Smelter List,
Checker, Product List, and Smelter Look-up（The role of each sheet will be explained on the next page.)

Language choices are
restricted to English, Japanese,
Chinese and Korean

Confirm revision no.

You need to fill in THREE sheets: Declaration, Smelter List, and Product List.

9/40

2. Outline of CRT Rev. 2.11: Role of Each Sheet
Role of each sheet• Revision
Record of revisions• Instructions Explanation of background and how to fill in the sheets• Definitions
Definitions of terminology• Declaration Company information (Q1-6 and A-I)
<REQUIRED>• Smelter List List of smelters (refiners)< WHERE NECESSARY*1 >• Checker
Checks that all the necessary information has been filled in<CHECK REQUIRED*2 >• Product List List of target products<WHERE NECESSARY*3>• Smelter Look-up Smelter Look-up list*4(List of smelters (refiners) at the time of CRT issuance)
Notes:*1 Fill in for those metals to which you responded “Yes” for Q1*2 Fill in any areas marked in red on the Checker Sheet*3 Fill in where the scope is “B: Product”*4 List of smelters (refiners) at the time when the latest CRT was issued. The
latest list can be found on the RMI website.
* Please read the instructions and definitions before filling in the form.

10/40

2. Changes to CRT Rev. 2.11
*1 Rev. 2.1 was initially issued on

Rev. 1.1 (issued 21 December 2018)
May 13, 2020 but revised
immediately due to bugs.
Rev. 2.0 (issued 30 October 2019)➔ Rev. 2.11*1 (issued 19 May 2020; latest version)
Smelter List update and bug fixes only Bug on Line 57 of the Checker in CRT Rev. 1.1 fixed The following bugs in CRT Rev. 2.11 can be ignored• If you choose A. Company for Declaration Scope and Class on the
Declaration sheet, Product List Line 56 in the Checker will be highlighted
in red.
• In Row C in the Smelter List (Smelter Look-up), if you select “Smelter not
yet identified,” Row D (Smelter Name) will be grayed out and Row E(Smelter Location) will remain blank. (According to the Instructions(Smelter Look-up, Line 49), in this case “Unknown” will be automaticallyentered.)You can follow the same instructions for Rev. 2.11 as for Rev. 1.1.
11/40

3. How to Complete the CRT:
3.1 Composition of the Declaration Sheet
The Declaration Sheet is composed ofthree blocks.

Ⓐ

Ⓑ

Ⓒ

Ⓐ 14 company information itemsⒷ 6 questions related to the status ofyour cobalt use (summary ofprimary supplier information)Ⓒ 9 questions related to your cobalt
sourcing policies and actions
12/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓐ Company Information
All items marked with an asterisk
must be completed (highlighted inyellow)
Use the pulldown menu to choose
from options A to C. The party
making the report (your company)
decides the Description of Scope,but in some cases it is decided by
the customer.

DD-MMM-YYYY format
Example: 01-May-2020

A. Company
B. ProductApplies to ALL your company’s products
Applies only to SOME of your products→ Fill in the Product List Sheet
C. User defined Applies within the scope defined by your company→ Specify the product scope in the “Description of scope” field
13/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓐ Company Information
If you choose B. Product (or List of Products), the line “Go to Product List
tab to enter products this declaration applies to” will appear as below,
along with a “Click here” instruction under B. Product.

Clicking as instructed will take you to the Product List Sheet, where you will
fill in the manufacturer’s product number, etc. (details on the next page).

14/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓑ Cobalt Use Status
Answer each question using the pulldown menu. If you answered “No” to Q1,
you don’t need to respond from Q2 onward.
1) Is any of the cobalt intentionally added orused in the product(s) or in the
production process?
2) Do any of the smelters in your supply
chain source the cobalt from a ConflictAffected and High-Risk area?
3) Does 100 percent of the cobalt originate
from recycled or scrap sources?
4) What percentage of relevant suppliers
have provided a response to your supply
chain survey?
5) Have you identified all of the smelters
supplying the cobalt to your supply chain?
6) Has all applicable smelter information
received by your company been reported
in this declaration?
15/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓑ Cobalt Use Status
1) Is any of the cobalt intentionally added or used in the product(s) or in
the production process?
Yes Answer “Yes” if cobalt has been intentionally added or usedbecause it is necessary to the functionality, specifications, or
production of a product, regardless of the amount.
No Answer “No” if cobalt has NOT been intentionally added or used,even if products include trace-level cobalt contaminants.
Unknown If you don’t know whether cobalt has been intentionallyadded or used, answer “Unknown.”
1. If even one of the CRTs you have collected from suppliers answers “Yes”, youranswer here must also be “Yes.”
2. If all of the CRTs you have collected from suppliers answer “No, your answer
will be “No.”3. In cases other than the above, answer “Unknown.”
If you answered “Yes” to Q1, you must also answer Questions 2-6 and A-I.
16/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓑ Cobalt Use Status
2) Do any of the smelters in your supply chain source the cobalt from a
Conflict-Affected or High-Risk Area? （OECD Due Diligence Guidance, see
definitions tab）
Yes
If your smelters source from a CAHRA (describe in Comments field)No
If your smelters don’t source from a CAHRA
Unknown
If you don’t know whether your smelters source from a CAHRA
DRC or adjoining countries only If your smelters source only from the DRC or
adjoining countries
If there is a broad range of answers
in the CRTs you have collected, use
the Comments field as shown on
the right.
DRC+9: DRC or adjoining countries
only

Collation o f multiple CRTs
Yo ur company's answer
Yes
No Un known DRC+9 Answer
Co mments
○
○
○
○
Yes
including DRC+9
○
○
○
Yes
○
○
○
Yes
including DRC+9
○
○
○
Yes
including DRC+9
○
○
Yes
○
○
Yes
○
○
Yes
including DRC+9○○
Unknown
○
○
DRC+9
○
○
DRC+9 inclu ding Unkno wn○○○
DRC+9 including Unknown

17/40

3. How to complete the CRT:
3.1 Declaration Sheet Ⓑ Cobalt Use Status
3) Does 100 percent of the cobalt originate from recycled or scrap
sources?
Yes
If 100% of the cobalt comes from recycled or scrap sources
No
Some of the cobalt comes from natural (mined) resources
Unknown Unclear whether 100% of the cobalt comes from recycled or
scrap sources
If all of the suppliers from which you have received a CRT answer “Yes,” youranswer will be “Yes.” If even one answers “No”, your answer here must also be
“No.”

18/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓑ Cobalt Use Status
4) What percentage of relevant suppliers have provided a response to yoursupply chain survey?
Choose one of the following options according to the percentage of
disclosures received from all relevant suppliers.
-

100％
Greater than 90%
Greater than 75%
Greater than 50%
50% or less
None
※ Regardless of CRT Question 4 answers received from suppliers

Suppliers excluded from the scope of the CRT• Suppliers of equipment, tools, consumables, and other products outside thescope of the CRT• Suppliers or parts and materials which clearly do not contain cobalt
Note: Surveys must be continued until the response rate is 100%.

19/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓑ Cobalt Use Status5) Have you identified all of the smelters supplying the cobalt to yoursupply chain?
YesNo

If you have identified all of the smelters
If you have not identified even one supplier supplying the cobalt to yoursupply chain
Unknown If you don’t know whether you have identified all the smelters

You can only answer “Yes” if you meet all four of the conditions below:① You have received CRTs from all the relevant suppliers (=your answer
to Q4 was 100%).
② The answer to Q4 in all the CRTs you received was 100%.
③ The answer to Q5 in all the CRTs you received was “Yes.”④ The answer to Q6 in all the CRTs you received was “Yes.”
You must also have identified all smelters through your due diligence.
20/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓑ Cobalt Use Status6) Has all applicable smelter information received by your company beenreported in this declaration?
Yes

You have reported all applicable smelter information received by yourcompany
No You have not reported some of the applicable smelter information
received by your company。
Unknown You don’t know (You should not need to select this option.)
The answer will usually be “Yes,” but it may be “No” if you have not reported
all the applicable information because of an obligation to protect supplierconfidentiality, etc.

21/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓒ Policies and Actions
Choose the pulldown to answer each of thenine questions on your company’s policies
and actions in relation to cobalt sourcing.

A. Have you established a publicly available cobalt sourcing
policy?
B. Does your policy cover, at a minimum, all risks in the OECD
Due Diligence Guidance Annex II Model Policy, as well as
the worst forms of child labor?
C. Have you implemented due diligence measures for cobalt in
the declaration scope indicated above?
D. Do you require suppliers to exercise due diligence over thecobalt supply chain in accordance with the OECD Due
Diligence Guidance?
E. Do you require your direct suppliers to source cobalt fromsmelters whose due diligence practices have beenvalidated by an independent third party audit program?
F. Do you require suppliers' due diligence practices to cover, ata minimum, all risks in the OECD Due Diligence Guidance
Annex II Model Policy, as well as the worst forms of childlabor?
G. Does your company conduct cobalt supply chain survey(s)of your relevant supplier(s)?
H. Do you review due diligence information received from yoursuppliers against your company’s expectations?

Unrelated to disclosures received fromsuppliers

I. Does your review process include corrective action
management?

22/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓒ Policies and Actions
A. Have you established a publicly available cobalt sourcing policy?
YesNo

If your company has established such a policy
If your company has NOT established such a policy

B. Does your policy cover, at a minimum, all risks in the OECD Due Diligence
Guidance Annex II Model Policy, as well as the worst forms of child labor?

Yes Yes, it does
No No, it doesn’t

See next page for details on
what comprises “the worst
forms of child labor.”
23/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓒ Policies and Actions
International Labour Organization (ILO)
C182 – Worst Forms of Child Labour Convention, 1999
https://www.ilo.org/dyn/normlex/en/f?p=NORMLEXPUB:12100:0::NO::P12100_ILO_COD
E:C182(a) all forms of slavery or practices similar to slavery, such as the sale andtrafficking of children, debt bondage and serfdom and forced orcompulsory labour, including forced or compulsory recruitment of children
for use in armed conflict;(b) the use, procuring or offering of a child for prostitution, for the productionof pornography or for pornographic performances;(c) the use, procuring or offering of a child for illicit activities, in particular forthe production and trafficking of drugs as defined in the relevantinternational treaties;(d) work which, by its nature or the circumstances in which it is carried out, islikely to harm the health, safety or morals of children.
24/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓒ Policies and Actions
C. Have you implemented due diligence measures for cobalt in
the declaration scope indicated above?
Yes If you have implemented such measures
No If you have not implemented such measures

D. Do you require suppliers to exercise due diligence over thecobalt supply chain in accordance with the OECD Due
Diligence Guidance?
Yes If you require suppliers to exercise due diligence
No If you do not require suppliers to exercise due diligence
25/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓒ Policies and Actions
E. Do you require your direct suppliers to source cobalt from smelters whose due
diligence practices have been validated by an independent third party audit
program?
Yes Yes, you do.
No No, you don’t

F. Do you require suppliers' due diligence practices to cover, at aminimum, all risks in the OECD Due Diligence Guidance Annex II
Model Policy, as well as the worst forms of child labor?
Yes Yes, you do.
No No, you don’t

26/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓒ Policies and Actions
G. Does your company conduct cobalt supply chain survey(s) ofyour relevant supplier(s)?
Yes, CRT

If you conduct cobalt supply chain surveys of your relevant
suppliers using the CRT format
Yes, Using Other Format (Describe)
If you conduct surveys of your relevant suppliers using
another format (describe in Comments field)No
If you don’t conduct cobalt supply chain surveys

27/40

3. How to Complete the CRT:
3.1 Declaration Sheet Ⓒ Policies and Actions
H. Do you review due diligence information received from yoursuppliers against your company’s expectations?
Yes If you do review due diligence information received
from your suppliers against your company’s
expectations
No If you don’t
I. Does your review process include corrective action
management?
Yes If your review process does include corrective action
management
No If it doesn’t
28/40

3. How to Complete the CMRT:
3.2 Smelter List Sheet ーStructureーOn the Smelter List, you enter information on all smelters in your supply chain. The sheet
comprises 17 items.

1 2

3

4

5

6

7

8

1. Smelter Identification Number Input
Field
2. Metal (*)
3. Smelter Look-Up (*)
4. Smelter Name (1)5. Smelter Country (*)
6. Smelter Identification
7. Source of Smelter Identification
Number
8. Smelter Street
9. Smelter City

9

10

11

12

13

14

15

16

17

10. Smelter Facility Location: State / Province
11. Smelter Contact Name
12. Smelter Contact Email13. Proposed next steps
14. Name of Mine(s) or if recycled or scrap sourced,
enter "recycled" or "scrap"
15. Location (Country) of Mine(s) or if recycled or
scrap sourced, enter "recycled" or "scrap"
16. Does 100% of the smelter’s feedstock originate
from recycled or scrap sources?
17. Comments(*) Compulsory fields
29/40

3. How to Complete the CMRT:
3.2 Smelter List Sheet ーPreparationーBefore filling in the Smelter List, please make the following preparations: List all the smelters from which you have received CRTs
 Use CID numbers, etc., to remove duplications (name identification)
 If your list contains non-SSN smelters without CID numbers, check on theirwebsite, etc., that they really are operating smelters (due diligence) Delete trading companies and other businesses which are clearly not smelters

In some cases, smelters that were SSNs may have become non-SSNs. For
example, they may have:• Ceased to operate as a smelter• Amalgamated with another smelter• Been discovered not to be a smelter
The SSNs on the Smelter Look-up Sheet are as at the time of CRT issuance, andthere are some cases where the RMI has subsequently recognized a smelter as an
SSN and given it a CID number (you can check this on the RMI website). Even inthese cases, for the purposes of this CRT, the smelter will be deemed “Smelter
not listed.”

30/40

3. How to Complete the CMRT:
3.2 Smelter List Sheet ーData Entryー① If you already know the CID number
When you enter the CID number into Field A, Fields B, C, E, F, G, I, and J will be
automatically populated.
We recommend copying and pasting CID numbers into Field A.

Enter the CID number here

Fields B, C, E, F, G, I, and J will be populated
automatically

31/40

3. How to Complete the CMRT:
3.2 Smelter List Sheet ーData Entryー② If you don’t know the CID number
If you select cobalt in Field B and chose the appropriate smelter name in Field C, Fields E, F,
G, I, and J will be populated automatically.
You can also copy and paste into Fields B and C, but if the data in Field C does not exactly
match the data in the Smelter Look-up field on the Smelter Look-up Sheet, Fields E, F, G, I,
and J will not be populated automatically even if it is the right the SSN (CID number).
③ If there is no selection option in Field C (non-SSN smelter)
Once you have selected cobalt in Field B, select “Smelter not listed” in Field C, and enter
the smelter name in Field D and the smelter country in Field E. All these fields arecompulsory, but please also populate Fields H-P to the best of your ability.

④ If you cannot identify the smelter
Select cobalt in Field B and chose “Smelter not yet identified” in Field C.

②
③
④

32/40

3. How to Complete the CRT:
3.2 Smelter List Sheet ーData EntryーIf the Declaration Scope or Class is B. Product (or List of Products),
you must complete the Product List.

Manufacturer’s Product Number (compulsory): Enter the product numbers for the relevant products
Manufacturer’s Product Name: Enter the product nameComments: Enter comments where necessary

33/40

3. How to Complete the CRT:
3.4 Checker Sheet
After completing the Declaration Sheet, Smelter List Sheet, and Product List
Sheet, please use the Checker Sheet to check that you have populated all thenecessary fields.

③
Complete→②
Incomplete→①① Select Checker Sheet to confirm your data entry.
② Areas in green are complete; areas in red are incomplete.
③ When the “Required fields remaining to be completed” value is 0, yourdata entry is complete.
34/40

4. RMI Website: Outline

 RMI Home Page
http://www.responsiblemineralsinitiative.org/
 Here you can access the following information (as of 13 May 2020)①Download the CRT Template② Cobalt Smelter/Refiners List
a. Export the Smelter Reference List
b. Download Conformant Cobalt Refiners or Active Cobalt Refiners③ FAQ (Frequently Asked Questions)35/40

4. How to use the RMI website: CRT① Download the CRT template(1) Select REPORTING TEMPLATES from the tab at
the top of the page and choose Cobalt Reporting
Template from the dropdown menu.

(2) The first time you access the page, read theTerms & Conditions and agree by clicking I accept at
the bottom.

(3) Click Download CRT.

･･･

36/40

4. RMI Website: Cobalt Smelter/Refiners List
② (a) Export the Smelter Reference List
(1) Select REPORTING TEMPLATES from the top
menu and then select Cobalt Reporting
Template from the dropdown menu.

(2) Under Cobalt Reporting Template,click HERE.

(3) When the Cobalt Smelter Reference
List comes up, click Download Data.

↓Cobalt Smelter Reference List

37/40

4. RMI Website: Cobalt Smelter/Refiners List
② (b) Download Conformant Cobalt Refiners or Active Cobalt Refiners
1) Select ASSURANCE PROCESS from the top
menu on the main page, then select Smelter &Refiners from the dropdown menu, then Cobalt
from that dropdown menu.

(2) Under Cobalt Refiners List, click View Conformant
Cobalt Refiners or View Active Cobalt Refiners.

↓Active list

↓Conformant list

Next page
38/40

4. RMI Website: Cobalt Smelter/Refiners List
(3) When your chosen Refiners list appears, click Download Data.

A CRUDE COBALT REFINER field was added to the Active List only on 13 May 2020. Crude
cobalt refiners are refiners engaging in primary refining near the mine.
39/40

4. RMI Website: FAQ③ FAQ (Frequently Asked Questions)(1) Select REPORTING TEMPLATES from thetab at the top of the page and choose
Cobalt Reporting Template from thedropdown menu.

(2) Scroll down the Cobalt Reporting
Template section to the FAQs.

Here are the FAQs

40/40