Cobalt has been the topic of media articles, NGO-sponsored reports and heavy discussion for years, but when demand for the mineral skyrocketed, so did corporate interest — leaving many wondering how cobalt would fit into future conflict mineral rules.

While it started as a pilot project, the Responsible Mineral Initiative (RMI) has announced plans for a formal cobalt reporting template. The RMI released a pilot Cobalt Reporting Template (CRT) on March 1, marking the start of a six month pilot phase for the new reporting template.

The pilot phase will run until August 31, 2018. The RMI plans to survey users on the CRT from September 1 to October 1, 2018 and share results at the RMI Annual Conference and Members Meeting, which starts at the end of October. By the end of the calendar year, they plan to make a decision on the CRT’s future and possible changes.

The CRT, already available for download online, provides a standardized template for tracking cobalt, similar the Conflict Mineral Reporting Template’s (CMRT) role as a resource to track tin, tungsten, tantalum and gold (3TGs). The CMRT is different than the CRT in that it follows the IPC-1755 standard for conflict minerals and doesn’t include cobalt.

Download The Conflict Mineral Handbook: Your Guide to Compliance in 2018 to learn more about managing conflict mineral reporting.

Cobalt was almost the fifth conflict mineral, joining the 3TGs when Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act was introduced in the United States, but it was met with corporate resistance. Cobalt is also primarily processed as a byproduct of copper and nickel mining — adding a level of complexity when identifying and validating sources.

The Responsible Cobalt Initiative (RCI) and the RMI have also announced plans to develop a joint pilot audit program for cobalt refiners. Given the corporate and consumer desire to source responsibly, an audit scheme will be needed in the very near future to ensure businesses have validated sources to buy from.

In the coming months, it’s expected a number of companies will adopt the pilot template to gather data, assessing how available cobalt sourcing information is, and to gather potential cobalt processors’ details.


The Democratic Republic of the Congo (DRC) is mineral rich in 3TGs and cobalt alike. Cobalt production can be tied to human rights abuses, including financing armed conflict and child labor. A 2017 Amnesty International report, Time to Recharge, said 20 percent of the cobalt from the DRC is hand-mined. The report documented the mining process and children and adults who worked in unsafe conditions with a risk of fatal accidents.

The demand for cobalt has been on a steady rise, as the mineral is used in batteries for cell phones and electric vehicles. The increased demand has resulted in the cost of cobalt tripling to $80,000 per ton, increasing the attraction to cobalt production in the DRC.

As reports of cobalt production contributing to human rights abuses have increased, so has the responsibility for companies using cobalt in products to conduct proper due diligence to ensure responsible sourcing. As a result, more and more companies are examining their supply chains for cobalt, alongside 3TGs.

Download Ethical Sourcing: Your Guide to the Expanding Landscape to learn about other materials you should include in your responsible sourcing initiatives.

Companies may need to complete a materiality assessment to identify if cobalt is used in products and due diligence should be performed to ensure supply chain claims can be validated.

Assent Compliance offers solutions to address scoping concerns. Our team of regulatory experts can work with you to identify the best methods to ensure alignment with industry standards and reporting on applicable materials. We also provide solutions to survey your supply chain by providing automated data collection, validation and management, streamlining communications with your supply chain.

Learn more about Assent’s Conflict Minerals Solution and how we streamline communications with your supply chain.

Jared Connors
Director, Sustainability

Jared is focused on helping companies achieve their corporate social responsibility (CSR) goals through increased understanding and mitigation of risk. His 12 years of leadership in human rights, anti-bribery  Read More

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