Conflict Minerals Due Diligence for Metal Trims: 3TG, CMRT and Evidence

In the past two years many apparel brands have sent suppliers a spreadsheet asking whether your products contain tin, tantalum, tungsten or gold, which smelters those metals come from, and whether any of them originate in conflict-affected and high-risk areas. This is the conflict minerals part of supply-chain due diligence. A factory making hang tags, woven labels, care labels and bags usually answers that it works with no metal at all — but a wrongly completed form travels back up the chain to the brand. This guide sets out what to verify, what evidence to keep and the mistakes to avoid.

It runs in six parts: who pushes the form down the chain, which trims are genuinely in scope, how to complete it, what to do when upstream data cannot be obtained, how to keep files and traceability, and finally five common mistakes with a preparation list.

1. Why the Client Asks: the Form Comes Down the Supply Chain

• Two drivers, rules and brand promises: the EU conflict minerals regulation requires EU importers to run supply-chain due diligence on tin, tantalum, tungsten and gold, while the US disclosure rules have shifted several times and now lean more on voluntary brand commitments and investor pressure.
• How it reaches you: the brand sends its annual form to the garment factory, which splits it across fabric, hardware and trim suppliers — so what you receive was not designed with you in mind.
• Nobody expects a mine audit: no brand asks a trim supplier to investigate mining sites in central Africa. What is wanted is a traceable answer: is it present, where does it come from, on what evidence.

2. Which Trims Are Actually in Scope: Go Through the Bill of Materials

Treat the table as a checklist to tick against your own bill of materials; it saves several rounds of follow-up questions that a blanket yes or no would invite.

3. How to Complete the Form: Three Answers and Levels of Evidence

• First, no 3TG present: the basis is the bill of materials plus the process route — no plating, no solder, no gold, no chips. Answer none and attach the supporting file.
• Second, 3TG present with upstream data: complete the smelter name, country of origin, whether it sits in a conflict-affected or high-risk area and whether it has passed a responsible minerals audit.
• Third, 3TG present but no upstream data: state unknown or unsupported honestly, and attach an improvement plan — which supplier you will ask, by when, and which process you plan to switch to.
• Evidence, strongest first: an upstream written statement with a smelter list, then purchase invoices and batch records, then your own declaration, and only last a verbal answer.
• Use the right template version: the industry templates such as CMRT are revised each year, and an outdated version is usually sent back, so confirm which revision the client wants before starting.

4. Four Practical Routes When Upstream Data Is Missing

• Route one, ask for an annual statement: start with the plating shop and the solder supplier — one annual written statement naming the countries of origin for tin is far faster than chasing batch-level data.
• Route two, put 3TG in the purchasing specification: new suppliers answer the question at quotation stage and existing ones catch up at the annual review, so you stop asking on every order.
• Route three, change the process where you can: plating-free finishes, tin-free solder or a mechanical clasp shrink the scope at source and persuade a client far better than another year of unknown.
• Route four, replace one-off effort with an annual review: attach the data to the material code so a change of material, plating process or supplier triggers a refresh and the answers stay consistent year on year.

5. Files and Traceability: What to Keep and for How Long

• Three files as a minimum: the upstream written statement, the purchase invoice and the batch or incoming record — traceability only exists when the three agree.
• Make each statement findable: material code, supplier name, issue date and the year it covers, so you never end up with a stack of undated statements that match nothing.
• Retention follows the client requirement: most brands ask for three years or more with retrieval on demand, so confirm before adopting anything shorter.

6. Five Common Mistakes and a Preparation List

• Mistake one, we use no metal: plating, solder and tooling all count — look at the process, not only the material list.
• Mistake two, tick not applicable and move on: not applicable needs a bill of materials and process route behind it, and clients usually ask for the basis.
• Mistake three, treating plating as someone else's business: surface finishing is your own process step, the tin in the coating and solder is 3TG, and pushing it upstream does not close the question.
• Mistake four, assuming paper goods need no attention: paper tags, woven labels and paper bags are usually out of scope, but the conclusion has to be proved from the bill of materials — and smart tags with NFC or RFID need separate confirmation of chip and antenna origin.
• Mistake five, sign it and deal with it next year: the forms are filed and compared across years; an inconsistency is harder to explain than an honest unknown, and costs more trust.
• Preparation list: flag every component and tool with plating, solder, metal or electronics in the bill of materials; give each metal part one upstream statement and its batch range; review annually and update immediately on a material or supplier change; file forms, replies and evidence together by year; confirm chip origin separately for smart tags.

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