Conflict minerals due diligence in China after the RBA ban
What stopped, what is still open, and how to keep reporting this cycle.
On 5 August China designated the Responsible Business Alliance, so companies in China cannot work with it. RMAP assessments, VAP audits and RLI programmes sit underneath the RBA, so for Chinese sites those have stopped. Whether a supplier can still fill in a CMRT for you is untested, and that is the question most people are asking. Your reporting obligations have not changed. The route to the data has.
What's inside
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.
Are we non-compliant if we cannot collect the data?
No. The SEC rule points at the OECD framework rather than at any questionnaire, so losing RMI access does not put you in breach. You show that you looked, took a reasonable alternative route, and recorded it.
Should we drop our Chinese suppliers?
Usually the wrong default. Abrupt termination carries its own risk under the Chinese measure, and you lose the visibility you have.
How long will this last?
Nobody knows. No guidance has been published and there is nothing comparable to compare it to. Our own guess is months rather than weeks.
Free access while this lasts. 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, what is still undefined, and what it changes for suppliers who can no longer work with RBA and RMI programmes.
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