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Reasonable Country of Origin Inquiry (RCOI) is often described as a requirement.
In practice, it is a litmus test for due diligence maturity.
During audits and customer reviews, RCOI is rarely evaluated on whether it exists. It is evaluated on whether it makes sense, whether it is documented, and whether it aligns with actual supplier behavior.
This article focuses on how RCOI is structured in programs that consistently withstand conflict minerals audits—and where most programs fail quietly.
What “Reasonable” Means in Regulatory Terms
“Reasonable” does not imply minimal effort. It implies risk-based inquiry proportionate to sourcing complexity.
Under U.S. Securities and Exchange Commission guidance for Dodd-Frank Section 1502, companies are expected to determine whether there is reason to believe 3TG may have originated from covered countries, based on available information and supplier engagement
Similarly, the European Commission’s Conflict Minerals Regulation emphasizes documented inquiry and ongoing risk assessment rather than one-time conclusions
Auditors evaluate how conclusions were reached, not whether they were convenient.
Defining Supplier Coverage Before Outreach Begins
Audit-resilient RCOIs start with a clear definition of who is in scope.
Strong programs:
- Identify suppliers providing components likely to contain 3TG
- Explain why certain suppliers are excluded
- Document how supplier populations are reviewed year over year
Weak RCOIs often claim company-wide inquiry while only engaging a subset of suppliers—an inconsistency that surfaces quickly during review.
This issue commonly appears alongside broader conflict minerals reporting challenges
Documented Follow-Up and Escalation
One outreach attempt does not constitute inquiry.
Auditors expect to see:
- multiple contact attempts
- timelines for response
- escalation paths for non-responsive suppliers
When suppliers do not respond, defensible RCOIs explain:
- what alternative actions were taken
- whether risk assumptions changed
- why reporting proceeded despite gaps
The absence of follow-up documentation is one of the most frequent reasons RCOIs fail.
Consistency Between RCOI Findings and CMRT Data
RCOI conclusions must align with CMRT content.
Problems arise when:
- RCOI narratives suggest low risk
- but CMRTs list high-risk smelters or countries
- and no reconciliation is documented
This inconsistency signals that RCOI was treated as a formality rather than a decision framework.
Alignment between RCOI logic and CMRT reporting is emphasized in CMRT completion guidance
Country Risk Assessment as a Decision Input
Effective RCOIs explain why certain sourcing risks were ruled in or out.
This includes:
- acknowledging known conflict-affected regions
- explaining why suppliers were deemed low risk
- documenting assumptions used in country-level assessments
This is particularly important for gold, where sourcing routes and geopolitical risk evolve rapidly.
Recording Decisions, Not Just Outcomes
Auditors rarely challenge conclusions when the decision trail is visible.
Strong RCOIs document:
- why enhanced due diligence was or was not triggered
- how conflicting supplier inputs were resolved
- who approved key determinations
Weak RCOIs state outcomes without explaining the logic behind them.
This distinction is often highlighted in discussions around conflict minerals impact and accountability
Why RCOIs Fail Even When CMRTs Appear Complete
RCOIs commonly fail because they are:
- reused year after year without reassessment
- written after CMRTs are finalized
- disconnected from real supplier behavior
Auditors interpret this as post-hoc justification, not due diligence.
RCOI should inform CMRT conclusions—not retroactively support them.
Treating RCOI as an Ongoing Control
Manufacturers with stronger outcomes treat RCOI as:
- a repeatable workflow
- a trigger for supplier engagement
- a filter for escalation decisions
This approach aligns closely with modern expectations around traceability and transparency in responsible sourcing
RCOI stands or falls on documentation, not declarations.
Manufacturers that pass audits consistently embed RCOI into supplier engagement and CMRT review workflows, rather than treating it as a narrative exercise.
Solutions like Acquis Compliance help teams document RCOI activities, align inquiry results with CMRT data, and maintain a clear decision trail—strengthening conflict minerals due diligence without adding operational friction.