Conflict minerals due diligence in China after the RBA ban
What can continue, what may be affected, and what remains unclear.
On 5 August China placed the Responsible Business Alliance (RBA) on its countermeasures list. RBA's public statement says the countermeasures apply to entities and individuals operating within China, while RBA operations outside China are not affected.
RMAP assessments, VAP audits, RLI programmes and other RBA/RMI activities sit within the affected ecosystem. Their implications should be considered separately: the designation should not be interpreted as meaning that every RBA/RMI-linked tool or activity has automatically stopped.
RMI continues to make its Minerals Reporting Templates available. On 19 August it also released versions of each MRT without RMI logos and branding, which it says are functionally identical to the versions released in April. Suppliers may still take different approaches in practice, so companies should be prepared for reluctance or disruption without assuming that use of an MRT is itself unavailable.
What's inside
Using a reporting template is not the same as every other RBA/RMI activity
CMRT, EMRT and other MRTs are formats for exchanging information. Using a reporting template, participating in an RBA or RMI programme, and engaging directly with the RBA should not automatically be treated as equivalent.
RMI reporting templates remain available, including the new unbranded versions published on 19 August. View the current MRTs on the RMI website.
Who is this for?
Responsible sourcing, compliance and procurement teams with Chinese suppliers or facilities, and anyone filing a Form SD this cycle. Written to be shared, including with suppliers working out what they can and cannot do.
Can Chinese suppliers still complete CMRT, EMRT or other MRTs?
RMI continues to make its Minerals Reporting Templates available, including new unbranded versions. The important distinction is between using a reporting format and other forms of participation or direct engagement with RBA/RMI. Suppliers may still be cautious in practice, so companies should be prepared for different responses.
Are we non-compliant if we cannot collect the data?
A disruption to one particular due diligence route does not remove the underlying obligation. Companies still need to collect appropriate information, assess risk and document the basis for their decisions.
Should we drop our Chinese suppliers?
Usually the wrong default. A disruption to one due diligence route does not by itself mean the supplier relationship needs to end. First establish what information remains available, what is missing, and what alternative steps are reasonable for your process.
How long will this last?
The position is still developing and further public guidance may change how individual processes are handled.
Free access while this situation develops. Look up the facilities you work with, see what is already on file, and run your own framework against them.
General information, not legal advice.
Background · August 2026
Want the story behind the 5 August decision?
Our news post covers what was decided, which RBA/RMI processes may be affected, what remains unclear, and what it means for due diligence involving Chinese suppliers.
Get the briefing
Fill in the form and we'll send it straight to your inbox.