EMRT 2.0: Which Critical Minerals Are Included in RMI’s Extended List?
The duty of care has entered a phase of expansion, introducing new reporting requirements for companies worldwide. Securing the supply of critical minerals, which are essential for the global energy transition, has become central to both economic and geopolitical concerns. While the focus has historically been on the “3TG” minerals (tin, tantalum, tungsten, and gold), the scope now extends to other minerals whose extraction raises similar social, environmental, and ethical challenges.
Markets are demanding greater transparency regarding these vital materials, especially in industries such as electronics, automotive, aerospace, and defense. This trend is further amplified by persistent risks of human rights violations and links to armed conflicts in supply chains.
In this context, the Responsible Minerals Initiative (RMI) has published a major update to its traceability standard: EMRT 2.0. This article analyzes the model in detail, explains its purpose, introduces the new integrated minerals, and explores the concrete implications for companies’ reporting and strategy.
What Is EMRT 2.0?
To fully understand the significance of EMRT 2.0 (Extended Minerals Reporting Template), it is helpful to review its origins. As due diligence obligations expand beyond the 3TG minerals, the extended mineral declaration model (EMRT) has become a free, standardized reporting tool developed by the Responsible Minerals Initiative (RMI). The RMI is a global organization that supports companies in responsible sourcing of minerals and in identifying risks throughout the supply chain.
It is important to note that EMRT was initially created by the Responsible Business Alliance (RBA), and the RMI is now an initiative under the RBA. The purpose of EMRT is to ensure the exchange of information across the supply chain regarding:
- The origin of minerals
- The treatment facilities used (foundries, refineries, and processors)
This exchange primarily occurs in a B2B context, allowing companies to trace materials before they reach consumer products. By facilitating this traceability, EMRT supports companies’ exercise of due diligence in line with the OECD Due Diligence Guidance for Responsible Supply Chains.
Historical Evolution of EMRT up to Version 2.0
EMRT’s evolution illustrates how RMI has adjusted its tool to meet the industry’s changing requirements, enhancing the effectiveness of its analysis. Key milestones include:
- EMRT 1.0 (October 2021): Focused on cobalt and mica.
- First update (June 1, 2022): Improved documentation, added a revision history section, and updated guidance for Question 3 of the declaration.
- EMRT 2.0 (April 25, 2025): A major revision reflecting the expanded scope, including:
- New definitions for transformers
- Specific guidance for data entry in the declaration and mine list tabs
- Simplified and clarified reporting processes for better traceability and efficiency
The continuous refinement of EMRT ensures that companies can maintain high data accuracy and improve information exchange across the supply chain.
Four New Strategic Minerals Integrated into EMRT 2.0
EMRT 2.0 significantly expands mineral reporting beyond the original cobalt and mica focus. The four additional strategic minerals now included are:
- Copper
- Natural Graphite
- Lithium
- Nickel
The inclusion of these minerals is closely linked to the battery market and the European supply chain requirements, particularly under the EU Battery Regulation (EU 2023/1542), which sets recycled content targets from 2031.
Comparison of old vs. new minerals:
- Previous EMRT minerals: Cobalt, Mica
- Newly added EMRT 2.0 minerals: Copper, Graphite, Lithium, Nickel
These additions reflect global priorities in sustainability, energy transition, and strategic industry needs.
Implications of EMRT 2.0: Reporting and Strategy
Direct Operational and Reporting Implications
The implementation of EMRT 2.0 introduces immediate operational implications for companies managing due diligence:
- Expanding the model increases the administrative workload and requires new verification processes.
- Companies must align the traceability of battery ores (Copper, Graphite, Lithium, Nickel) with the rigor previously applied to 3TG minerals.
- New definitions of transformers and required reporting for new minerals mean downstream companies must update processes and verify additional entities.
- Incorrect application exposes companies to the risk of non-compliant reporting, as RMI does not recognize modified versions of the template.
- Companies that previously collected data via AMRT (Additional Minerals Reporting Template) should gradually integrate it into EMRT 2.0 to avoid overwhelming suppliers.
Strategic Implications for EU Compliance
EMRT 2.0 also functions as a strategic tool for aligning with European energy transition and economic sovereignty goals:
- Mandatory reporting on critical battery minerals strengthens supply security.
- European battery production is projected to reach 2,475 GWh by 2033, driving exponential demand for lithium, nickel, graphite, and copper.
- A report by the Dubai Multi Commodities Centre (DMCC, Feb 2025) projects that global demand for lithium, cobalt, and nickel could increase 75-fold by 2050.
- EMRT 2.0 supports companies in meeting EU recycled content targets (6% lithium and 6% nickel by 2031) and managing dependency on concentrated refining sources such as China.
U.S. Compliance Considerations
- Growing Alignment with U.S. Regulatory Expectations: EMRT 2.0 is increasingly used by U.S.-based manufacturers and importers as part of responsible sourcing and supply chain due diligence programs, even though it is not a legal requirement.
- Support for UFLPA Compliance: The Uyghur Forced Labor Prevention Act (UFLPA) has led to stronger enforcement actions by U.S. Customs and Border Protection (CBP).
- EMRT data helps companies map supply chains, assess high-risk regions, and maintain documentation demonstrating “reasonable care.”
- Suppliers often rely on EMRT information when responding to CBP detention notices or forced-labor–related inquiries.
- Relevance to Inflation Reduction Act (IRA) Requirements: The IRA links certain EV and clean-energy tax incentives to sourcing rules for minerals such as lithium, nickel, and graphite.
- EMRT 2.0’s expanded mineral list helps manufacturers verify mineral origin and assess whether suppliers meet “free-trade agreement” criteria.
- Increasing Expectations from U.S. Customers and Auditors: Many U.S. OEMs and Tier-1 suppliers now request EMRT data as part of ESG audits, supplier onboarding, and annual compliance reviews.
- Strengthened Traceability and Risk Management: Using EMRT 2.0 reinforces compliance across multiple U.S. frameworks, including internal corporate policies, industry standards, and emerging reporting expectations around supply chain transparency.
Automating Traceability for EMRT 2.0
With the expansion of EMRT 2.0, manual methods (spreadsheets, ad hoc tracking) are increasingly inefficient due to:
- The volume of data generated by new minerals
- Frequent updates (EMRT 2.1 minor revision in October 2025; EMRT 3.0 expected in spring 2026)
- The need to track foundries and refiners according to updated RMI definitions
To manage these challenges, integrated EHS software is essential. Features include:
- Outsourced management of CMRT/EMRT reporting
- Dynamic supply chain mapping for new minerals
- Verification of foundry/refinery compliance using RMI reference lists
- Sustainable data management, ensuring auditability and traceability
Combining software with expert guidance ensures regulatory compliance and transparent critical mineral traceability. Solutions like BASSETTI GROUP’s TEEXMA for EHS provide these capabilities.
Best Practices for Implementing EMRT 2.0 in Your Supply Chain
Successfully integrating EMRT 2.0 into your supply chain requires more than simply filling out the template. Companies that adopt best practices can streamline reporting, improve compliance, and enhance supply chain transparency. Key strategies include:
Centralize Data Collection:
Use integrated software solutions to consolidate supplier information, mineral origin data, and treatment facility details. This reduces errors and ensures compliance with RMI standards.
Engage Suppliers Early:
Communicate the new EMRT 2.0 requirements to all upstream suppliers. Early engagement prevents delays and ensures accurate reporting of critical minerals such as lithium, nickel, copper, and graphite.
Automate Reporting:
Manual tracking of minerals across multiple suppliers is time-consuming and error-prone. Automation supports continuous traceability and allows your team to focus on analysis rather than data entry.
Align With Global Standards:
Ensure that EMRT 2.0 reporting complements other regulatory frameworks such as the OECD Due Diligence Guidance, the Dodd-Frank Act, and relevant EU directives. This dual alignment strengthens your ESG and compliance reporting.
Maintain an Audit Trail:
Keep a clear record of all supplier communications, mineral declarations, and updates. An auditable trail demonstrates due diligence and supports transparency for investors and regulatory bodies.
Regularly Update Processes:
EMRT 2.0 and RMI guidance are evolving. Schedule regular reviews of reporting processes to incorporate minor and major revisions efficiently, ensuring your compliance and traceability remain up-to-date.
Implementing these best practices not only ensures regulatory compliance but also positions your company as a leader in sustainable and responsible mineral sourcing, enhancing credibility with investors, partners, and customers.