Table of Contents
“Conflict-free” is one of the most misunderstood phrases in conflict minerals reporting.
In practice, many CMRTs labeled conflict-free are technically complete, procedurally weak, and compliance-fragile. They pass internal reviews, satisfy procurement timelines, and still collapse when subjected to customer validation or regulatory questioning.
False positives don’t announce themselves as errors. They hide behind clean templates, confident checkboxes, and inherited assumptions—until they’re challenged.
What Makes a CMRT a False Positive?
A CMRT becomes a false positive when the outcome suggests compliance, but the process cannot defend it.
This usually happens when:
- Declarations are accepted without validation logic
- Risk signals are overridden to meet deadlines
- Documentation exists but does not support conclusions
False positives are dangerous because they create misplaced confidence, not visible gaps.
1. “No 3TG Present” Claims That Ignore Product Reality
One of the most frequent sources of false positives is an unchecked “No” response to 3TG presence.
This becomes problematic when:
- The product category is known to use solder, plating, or electronic components
- No material or engineering review supports the claim
- Supplier responses contradict known manufacturing inputs
Auditors and customers increasingly cross-reference CMRT answers with product context. When those don’t align, conflict-free declarations unravel quickly.
2. CMRTs Completed Without Reviewing the Reporting Logic
Many CMRTs are treated as forms, not decision frameworks.
False positives emerge when:
- Suppliers select answers without understanding the implications
- Required follow-up questions are skipped
- “Unknown” responses are treated as low risk
This issue is amplified in large supplier populations, where CMRTs are collected at scale without structured review—one of the recurring issues outlined in broader conflict minerals reporting challenges
3. Smelter Data That Looks Complete but Isn’t Valid
A CMRT can contain dozens of smelters and still be non-defensible.
False positives often involve:
- Smelters that are no longer active
- Smelters mismatched to the declared metal
- Smelters not recognized by the Responsible Minerals Initiative
If smelter data cannot be validated against current reference lists, the conflict-free outcome becomes an assumption rather than a conclusion.
4. RCOI Statements That Don’t Match Supplier Outreach
Another common failure point is the disconnect between RCOI claims and supplier engagement evidence.
False positives arise when:
- RCOI language is generic and reused
- Supplier response rates are undocumented
- Escalation steps for non-responsive suppliers are missing
Even when a CMRT appears consistent, weak RCOI support undermines its credibility. This is especially relevant given regulatory expectations around Reasonable Country of Origin Inquiry
5. Overconfidence in “Conflict-Free” as a Final State
A subtle but critical issue: treating conflict-free as a permanent condition.
False positives occur when companies:
- Assume last year’s conclusion still applies
- Do not reassess suppliers after sourcing changes
- Ignore evolving geopolitical and smelter risk
Under U.S. Securities and Exchange Commission guidance for Dodd-Frank Section 1502, due diligence is expected to be reasonable and ongoing, not static
Similarly, the European Commission’s Conflict Minerals Regulation reinforces continuous risk evaluation rather than one-time declarations
6. CMRTs Reviewed in Isolation
False positives survive longest when CMRTs are reviewed without context.
Risk increases when:
- Compliance teams do not cross-check supplier history
- Procurement data is not considered
- No linkage exists between CMRTs and broader supply-chain transparency efforts
This isolation directly contradicts modern expectations around traceability and transparency in responsible sourcing
Why False Positives Are a Bigger Risk Than Missing Data
From a compliance perspective:
- Missing data signals immaturity
- False positives signal misjudgment
They can lead to:
- CMRT rejection by customers
- Mandatory corrective action plans
- Loss of credibility with OEMs
- Heightened regulatory scrutiny
In many audits, false positives—not gaps—are what trigger deeper review.
False positives don’t fail fast—they fail late.
Manufacturers that reduce risk focus on early validation, structured supplier review, and alignment between CMRT data and real sourcing conditions.
Strengthening how CMRT conclusions are reached—not just how forms are completed—is essential to maintaining defensible conflict minerals compliance.