Summary
Details
- Global
RMAP is not universally mandatory by law.
It can become practically required where:
A buyer requires RMAP Conformant smelters or refiners.
A company files conflict minerals disclosures.
A procurement process requires responsible mineral sourcing.
A lender or investor requires mineral due diligence evidence.
A customer requires RMI-aligned sourcing.
A company’s responsible sourcing policy requires RMAP participation.
For facilities, RMAP participation is generally voluntary. However, it can become commercially necessary where downstream customers require RMAP Conformant sourcing.
Deep dive
- What’s Required
- 1. Smelter, refiner, or recycler participation
- 2. Independent third-party assessment
- 3. Mineral-specific and all-minerals standards
- 4. Alignment with regulatory due diligence expectations
- 5. Public facility status
- Important Deadlines
- Current Status
- Penalties for Non-Compliance
- 1. Non-conformant status
- 2. Corrective action requirements
- 3. Loss of customer access
- 4. Contractual consequences
- 5. Regulatory and reputational risk
- Examples of Known Violations / Failure Modes
- Resources
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What’s Required
1. Smelter, refiner, or recycler participation
RMAP applies primarily to smelters, refiners, and recyclers that participate in the RMI assurance process. RMI defines standards for facilities participating in the Assurance Process.
Participating facilities may need to demonstrate:
Responsible mineral sourcing policies.
Due diligence management systems.
Supplier risk assessment.
Country-of-origin inquiry.
Transaction documentation.
Risk mitigation procedures.
Internal controls.
Records supporting mineral procurement.
Conformance with applicable RMI standards.
2. Independent third-party assessment
RMAP uses independent third-party assessment of facility-level management systems and sourcing practices. The assessment validates whether the facility conforms with RMI standards and applies a risk-based approach to responsible mineral procurement.
Facilities should prepare:
Policies and procedures.
Supplier lists.
Purchase records.
Chain-of-custody documentation.
Risk assessment files.
Corrective action evidence.
Staff interviews.
Site-level audit evidence.
3. Mineral-specific and all-minerals standards
RMI maintains standards for tin, tantalum, tungsten, gold and broader mineral supply chains. Its public list explains that RMAP Conformant facilities are assessed against the Global Responsible Sourcing Due Diligence Standard for Mineral Supply Chains and relevant mineral-specific standards.
Relevant minerals and materials may include:
Tin.
Tantalum.
Tungsten.
Gold.
Cobalt and other minerals covered by RMI tools and standards.
Recycled and secondary mineral flows where relevant.
4. Alignment with regulatory due diligence expectations
RMAP is not itself a law, but it is used to support compliance and due diligence expectations. RMI materials reference recognition activity linked to EU Regulation 2017/821, including European Commission assessment and recognition of equivalence for RMAP.
Companies should distinguish between:
RMAP conformance.
Legal compliance with conflict minerals rules.
EU conflict minerals due diligence.
OECD due diligence expectations.
Customer responsible sourcing requirements.
Product-level supply-chain claims.
5. Public facility status
RMI maintains public facility lists. Facilities listed as RMAP Conformant have been assessed through RMAP and validated against applicable RMI requirements.
Downstream companies may use the list to support:
Supplier due diligence.
Conflict minerals reporting.
Responsible sourcing programs.
Risk screening.
Customer disclosures.
Procurement decisions.
Important Deadlines
RMAP is voluntary, so there is no universal legal deadline.
Important timing points:
RMI standards are regularly reviewed and updated.
Minor revisions to relevant RMI standards were released on April 19, 2023.
The Global Responsible Sourcing Due Diligence Standard for Mineral Supply Chains was issued on December 15, 2021.
Facility assessment timing depends on application, audit, corrective actions, and final conformance decision.
Downstream companies should check current RMI facility lists before relying on a facility’s status.
Current Status
RMAP is active and globally used. RMI describes RMAP as its flagship program for helping companies make informed choices about responsibly sourced minerals in supply chains.
Current status:
Active global assurance process.
Administered by the Responsible Minerals Initiative.
Focused on smelters, refiners and recyclers.
Uses independent third-party assessments.
Supports mineral due diligence and responsible sourcing.
Includes public conformance lists.
Relevant to electronics, batteries, automotive, renewable energy, aerospace, industrial equipment and consumer goods.
Penalties for Non-Compliance
RMAP does not impose statutory penalties.
Possible consequences include:
1. Non-conformant status
A facility may fail to be listed as RMAP Conformant if it does not meet the applicable standard.
2. Corrective action requirements
Facilities may need to address gaps before conformance is validated.
3. Loss of customer access
Downstream companies may exclude non-conformant facilities from approved supplier lists.
4. Contractual consequences
Buyer contracts may require RMAP-conformant sourcing or equivalent due diligence evidence.
5. Regulatory and reputational risk
Weak mineral due diligence may increase risk under conflict minerals rules, human rights due diligence expectations, and ESG reporting.
Examples of Known Violations / Failure Modes
Typical failure modes include:
Claiming RMAP-conformant status without current listing.
Relying on outdated facility status.
Treating RMAP as proof of full legal compliance.
Missing country-of-origin information.
Weak supplier risk assessment.
Incomplete transaction records.
Poor corrective action follow-up.
Confusing facility-level conformance with product-level certification.
Assuming downstream suppliers are covered because one smelter is conformant.
Not screening for sanctions or high-risk sources.
Using RMAP evidence without broader OECD due diligence.
Making responsible mineral claims beyond the assessed scope.
Resources
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