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Few CMRT questions create more confusion than scope.
Many manufacturers submit company-level CMRTs believing broader coverage equals stronger compliance. Others move toward product-level CMRTs expecting deeper traceability to reduce risk.
Regulators don’t automatically prefer one format over the other. What they assess is whether the chosen scope is logical, defensible, and consistently applied.
Understanding how regulators interpret CMRT scope is essential to avoiding unnecessary scrutiny.
What “Company-Level” and “Product-Level” Actually Mean
A company-level CMRT represents sourcing and due diligence practices across an entire legal entity or business unit.
A product-level CMRT limits disclosure to:
- specific products
- product families
- customer-specific scopes
Neither approach is inherently right or wrong. Problems arise when scope claims exceed supporting evidence.
Why Scope Matters More Than Format
From a compliance standpoint, CMRT scope answers three critical questions:
- What sourcing is covered?
- What sourcing is excluded—and why?
- Can conclusions be defended with evidence?
Audits rarely fail because the “wrong” CMRT type was used. They fail because scope assumptions were unclear or inconsistent.
This issue frequently appears alongside broader conflict minerals reporting challenges
How Regulators Evaluate Company-Level CMRTs
Company-level CMRTs are commonly accepted—but only when supported by:
- centralized sourcing visibility
- consistent supplier engagement
- documented Reasonable Country of Origin Inquiry (RCOI)
Regulators may question company-level CMRTs when:
- product portfolios vary significantly
- high-risk materials are unevenly distributed
- supplier coverage is incomplete
In these cases, broad claims can weaken credibility instead of strengthening it.
When Product-Level CMRTs Carry More Weight
Product-level CMRTs tend to perform better when:
- sourcing varies by product or customer
- OEMs request customer-specific disclosures
- high-risk components require isolation
They allow companies to:
- limit assumptions
- target due diligence
- demonstrate precision
However, product-level CMRTs also require strong internal traceability. Without it, fragmentation can introduce inconsistencies.
This aligns closely with principles of traceability and transparency in responsible sourcing
The Role of RCOI in Defining CMRT Scope
Regardless of scope, RCOI quality is what regulators evaluate first.
Problems arise when:
- RCOI language implies company-wide diligence
- but supplier outreach only covers select products
This mismatch undermines both company-level and product-level CMRTs. A defensible scope must be matched by a defensible RCOI
Regulatory Perspective: US vs EU Expectations
Under U.S. Securities and Exchange Commission guidance for Dodd-Frank Section 1502, companies are given flexibility in scope—but are expected to explain and justify it
Under the European Commission’s Conflict Minerals Regulation, emphasis is placed on:
- risk-based scoping
- continuous assessment
- supplier-level accountability
In both cases, regulators trust clarity and consistency, not scope size.
Common Scope-Related Mistakes That Trigger Scrutiny
Regulatory and customer reviews often flag:
- company-level CMRTs used for customer-specific claims
- product-level CMRTs missing upstream supplier coverage
- unexplained scope changes year-over-year
These issues frequently appear alongside CMRT efficiency and governance gaps
How Companies Choose the Right CMRT Scope
Manufacturers with stronger outcomes typically:
- align CMRT scope with how sourcing decisions are made
- document exclusions explicitly
- maintain consistency across reporting cycles
- adjust scope only when sourcing changes justify it
Scope discipline is a maturity signal.
Regulators don’t trust CMRTs because they are broad or narrow. They trust them because they are clear. Manufacturers that align CMRT scope with real sourcing structures—and document that alignment—reduce audit friction and improve confidence across their supply chains.
Strengthening scope logic is often the simplest way to improve conflict minerals reporting defensibility.