Conflict minerals 3TG — the CMRT is not a spreadsheet, it is a living dossier.

The problem

«Every campaign I lose a month chasing incomplete CMRTs.»

Tracing the 3TG (tantalum, tin, tungsten, gold) back to the smelter of origin sounds reasonable when you describe it in a meeting room. Implementing it across a real chain is another game, because every tier-1 supplier has to request a CMRT from their tier 2, who have to request it from their tier 3, all the way down to the smelter. And along the way you run into:

1. Outdated template versions — RMI updates the CMRT periodically and many suppliers still send the version from three years ago.
2. Empty SOR IDs, or smelters declared under a trade name that does not appear on the RMI list.
3. «N/A» or blank answers that have to be chased by email, one by one, until the account manager remembers to ask their purchasing colleague.
4. Supplier changes mid-campaign that drag the whole cascade back to the start.
5. Consistency between what your BOM says (which SKU carries which 3TG) and what the CMRT records — wherever the BOM does not match, the SOR fails in audit.

The compliance manager knows this. They end up with two hundred spreadsheets in a folder, a summary sheet painted by hand, and the feeling that the next campaign will be exactly the same.

How it fits into the IRIS system

iLEAN does not add another spreadsheet — it replaces manual chasing with a nervous system.

The CMRT does not fail for lack of a template — the RMI one works. It fails because you are chasing 200 suppliers with 200 different versions of the same problem, and the information arrives late, incomplete and out of order. iLEAN acts as the putty that connects your BOM to the supplier chain and to the RMI list.

Connect chases the CMRT through the supplier's own channel — email, portal, form. The agent cross-checks it against the BOM and the RMI list, holds the doubtful batches, prepares the signable SOR. The person signs.

The two iLEAN pieces applied to 3TG:

• Connect — the app/portal where your supplier uploads the CMRT, yes; but also the email where they send a partial version, the messaging thread where the account manager asks for clarification, the transcribed call with the tier-2 buyer. Bidirectional: Connect also replies to the supplier in their language, with the exact question, when a field is missing — the person approves the reply before it goes out.
• Agent — it keeps the RMI Smelter Reference List alive, cross-checks every CMRT SOR ID against the list, flags conformant/non-conformant/doubtful, drafts the missing questions for the supplier, validates consistency between your product BOM and the CMRT the supplier declared, and consolidates the signable SOR (Specialized Disclosure) or the EU 2017/821 reporting, whichever applies.

And all of it under the three safety rings: capture enters ring 3 (power), cross-validation against the RMI list happens in ring 2, and the signed reporting lives in ring 1. The SOR that goes to the SEC is the one the person approved. Never the other way round.

See the full IRIS architecture →

Before and after

CMRT by hand vs. CMRT coordinated with iLEAN

Aspect	CMRT with spreadsheet + email	With iLEAN Connect + Agent
CMRT intake	200 spreadsheets in a network folder	Capture through the supplier's channel, anchored to the batch
SOR ID validation	Manual lookup in the RMI list	Automatic cross-check against a live RMI list
Chasing the gaps	Follow-ups from the compliance manager	Connect replies to the supplier in their channel and language
BOM ↔ CMRT consistency	Assumed — rarely cross-checked	Verified by the agent, alert if it diverges
Non-conformant smelter	Detected in audit, after the SOR	Detected at capture, batch put on hold
SOR / EU reporting	Manual consolidation at the end of the campaign	Dossier ready for signature, with traceable evidence

Impact estimate

Impact estimate for your plant — to be validated with your numbers.

The block below is an estimate to be validated against the concrete data of your operation. We put it forward so the committee has an order of magnitude; we refine it during the diagnostic.

• A mid-sized manufacturer (electronics, metalworking, aerospace) with 50-300 tier-1 suppliers carrying 3TG in their BOM, and one to three CMRT campaigns a year.
• Connect + Agent pilot on a single campaign and the tier-1 suppliers with the highest exposure. First value expected within a few weeks — the compliance manager receives the first batch of validated CMRTs without chasing anything by hand.
• Indicative payback between 4 and 9 months, depending on the current cost of the campaign (compliance FTE + purchasing team hours + delays in closing the SOR).
• Reduction in manual hours spent chasing and consolidating: ≥ 30 %, with room for more as further suppliers enter the loop.
• The hard lever is not losing the contract with the OEM that requires the CMRT on time, and shielding yourself against a failed SEC filing if you are listed or work with a listed company.

And the compliance manager's reasonable doubt

«What if the agent validates a non-conformant smelter and that ends up in my SOR?» — hallucination is a problem of free generation, not of anchored tasks. In tasks where the AI merely recontextualises a piece of data (extract the SOR ID from the CMRT, look it up in the RMI list, compare trade name and address), the best models brought the error below 1.5 % ^[1]. And even so, nothing goes out on its own: the agent prepares, the responsible person reviews and signs. The three rings exist precisely for this.

^[1] OpenAI paper «Why Language Models Hallucinate», 2025 — on the reliability of AI in anchored tasks.

Keep reading: EPR extended producer responsibility · REACH SCIP · CSDDD due diligence