On 5 August 2026 China named the Responsible Business Alliance (RBA) under its Anti-Foreign Sanctions Law. Companies and individuals in China are now prohibited from transactions, cooperation and other activities with the RBA, the organisation that runs the Responsible Minerals Initiative (RMI) and the Conflict Minerals Reporting Template (CMRT). For global supply chains with Chinese suppliers, the decision creates new questions around RBA-linked due diligence processes and how different activities may be affected.
Your own obligations under US SEC rules and EU regulations have not changed.
Quick answer
This is a practical situation note on what changed on 5 August 2026, what it may mean for different RBA and RMI processes, what remains unclear, and how to keep conflict minerals due diligence on Chinese suppliers running as the situation develops.
Who this is for: Compliance, procurement and sustainability teams filing CMRT, EMRT and AMRT with suppliers in China.
Not what you're looking for? This is general information, not legal advice. beSirius is independent and does not act for any government, regulator or enforcement authority.
Review your supplier risk on beSirius →What happened in China and the United States
3 August 2026, United States
The United States expanded its UFLPA forced labour import list and added more Chinese producers. Goods linked to a listed producer are, in practice, blocked from entering the United States.
5 August 2026, China
China named the Responsible Business Alliance under its Anti-Foreign Sanctions Law. Companies and individuals in China are prohibited from transactions, cooperation and other activities with it.
Three things to be clear about
1. Not every RBA and RMI process should be treated the same way
China’s measure restricts transactions, cooperation and other activities with the RBA. The practical implications depend on the type of activity involved. Using an industry reporting template, participating in an RBA or RMI programme, and cooperating directly with the RBA should not automatically be treated as equivalent.
RMI has since made unbranded versions of its Minerals Reporting Templates available, providing an additional option where suppliers have concerns about using RBA/RMI-branded materials.
2. How far the prohibition reaches has not been defined
The wider implications for different forms of RBA-linked engagement are still developing. RMI reporting templates remain available, including unbranded versions, while other activities should be considered separately rather than assuming the same position applies across every RBA and RMI process.
3. Your obligations are unchanged
US SEC conflict minerals rules and EU regulations still require you to carry out and disclose supplier due diligence. The duty is to make a reasonable inquiry, apply the OECD framework, and disclose what you found. It is not a duty to run one particular instrument, and it does not require a clean result. Where a supplier is unwilling or unable to use your usual route, or a particular assurance process is affected, you still need a reasonable alternative route to the information and a record of what you did.
Free trial
Need to know whether you can keep working with a Chinese supplier?
See what evidence you already have, what risks you can establish independently of RBA/RMI, and what is still missing.
How to keep your due diligence running
You keep the standards and reporting formats you already use. What matters now is how much you can establish before asking the supplier, what you still need from them, and what evidence you have if your usual route does not work.
Start from what is already known
Every supplier on the platform already has a Twin, so you are not starting from an empty questionnaire. A Twin is a single profile of what is known about that company. It holds adverse media, sanctions and watchlist screening, the supplier’s own public disclosures, records from industry associations and country databases, and anything that supplier has previously provided. A supplier that does not respond is no longer a blank.
Run your framework against it
Screening tells you, requirement by requirement, what is already answered, what is missing, and what needs attention, before you contact anyone. A framework is the set of requirements you measure a supplier against: a standard you already use, such as OECD, IRMA, RMI or RBA, or your own questionnaire. One Twin can be run against several frameworks, and one framework can be mapped to another, so a supplier answers once and that answer serves every framework and customer that needs it.
See how this works for CMRT, EMRT and AMRT automation.
Ask only for what is missing
Your request to the supplier drops from a full questionnaire to the specific points that are still open. The supplier provides those points directly to you, as its customer, into its own record. The information is collected for your due diligence process and stays in your process.
The same steps are set out, supplier by supplier, in our China RBA ban briefing.
What you end up with
A completed due diligence record
Origin, smelters and refiners, sourcing policies and the rest of your requirements, in the formats you already use, including CMRT and EMRT. You keep your format and your process.
A forced labour risk view without a single direct question
Built from your own framework together with public and supplier-provided information, and no other sources. The result is a risk level that tells you where to focus. It is a risk level rather than a clearance, and the judgement stays with you.
Briefing · August 2026
Want the full briefing on the 5 August decision?
Read the full briefing on what changed, which RBA/RMI processes may be affected, what remains unclear, and how to keep supplier due diligence running.
This is general information and not legal advice. beSirius is independent and does not act on behalf of any government, regulator, or enforcement authority.
