Supply chain managers at publicly listed US and EU companies routinely send CMRT requests to every supplier without checking whether the regulation applies. For brass fittings, the answer is almost always the same: brass contains copper and zinc — not tin, tantalum, tungsten or gold. This guide explains why, with full regulatory citations, so your compliance team can close the loop permanently.
Contents
- What Are 3TG Minerals?
- Dodd-Frank Section 1502 — Who It Applies To
- EU Conflict Minerals Regulation 2017/821
- The CMRT Template — What It Is and How It Works
- Does Brass Fall in Scope?
- What Brass Actually Contains
- Edge Cases: When a Brass Component Might Be Relevant
- Conflict-Affected and High-Risk Areas (CAHRAs)
- Brassland's Position & Available Documentation
- Frequently Asked Questions
What Are 3TG Minerals?
Conflict minerals legislation targets four specific minerals — collectively called 3TG:
These four minerals are specifically targeted because they are mined in significant quantities in conflict-affected regions — particularly the Democratic Republic of Congo (DRC) and adjoining countries — and their trade has historically funded armed conflict and human rights abuses. The goal of conflict minerals legislation is to create supply chain transparency that reduces the financing of such conflicts through mineral trade.
The regulation does not apply to all minerals — only to tin (and cassiterite, its ore), tantalum (and coltan/columbite-tantalite), tungsten (and wolframite), and gold. Critically, it does not apply to copper, zinc, aluminium, nickel or any other metal commonly used in precision fitting manufacture.
Dodd-Frank Section 1502 — Who It Applies To and What It Requires
Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (enacted July 2010) requires certain US-listed companies to disclose their use of conflict minerals. The implementing rule was adopted by the SEC in August 2012 (Final Rule 34-67716).
Who is subject to Dodd-Frank Section 1502?
- US Securities and Exchange Commission (SEC) reporting companies (issuers)
- That manufacture, or contract to manufacture, products
- Where 3TG minerals are necessary to the functionality or production of those products
- Annual disclosure via Form SD (Specialized Disclosure) filed with SEC
What does it require?
Companies in scope must undertake a "reasonable country of origin inquiry" (RCOI) to determine whether their 3TG comes from the DRC or an adjoining country. If it does, or if they cannot determine origin, they must conduct independent third-party audits of their supply chain and file a Conflict Minerals Report (CMR). Companies typically use the RMI CMRT template to collect data from their supply chain.
Brassland is an Indian manufacturer — not a US SEC reporting company. We are not directly subject to Dodd-Frank Section 1502. However, our US OEM customers who are SEC issuers have supply chain due diligence obligations, and they often request CMRT declarations from all their suppliers — including those supplying non-3TG components — as a blanket policy. We accommodate this with scope determination letters.
EU Conflict Minerals Regulation 2017/821
EU Regulation 2017/821 (the EU Conflict Minerals Regulation, or EU CMR) came into force on 1 January 2021. It establishes supply chain due diligence obligations for EU importers of tin, tantalum, tungsten and gold minerals and metals.
Scope of EU Regulation 2017/821
The EU CMR applies to:
- EU-based importers of 3TG minerals (cassiterite, coltan, wolframite, gold ores) and metals (tin, tantalum, tungsten, gold)
- Only when importing from conflict-affected and high-risk areas (CAHRAs)
- Above minimum annual import thresholds (e.g. 100kg for gold, 50t for tin metal)
The EU CMR does not apply to importers of finished articles made from 3TG metals (e.g. electronic components containing tin solder). It targets the upstream mineral and metal trade — the smelters and refiners, not the article manufacturers. This is narrower in scope than Dodd-Frank.
For brass fittings: the EU CMR is irrelevant. Brass is copper and zinc — neither is a regulated mineral. Brassland's EU customers importing brass fittings have no EU CMR obligations arising from those imports.
The CMRT Template — What It Is and How It Works
The Conflict Minerals Reporting Template (CMRT) is published and maintained by the Responsible Minerals Initiative (RMI), formerly known as the Conflict-Free Sourcing Initiative (CFSI). It is the industry-standard tool for collecting conflict minerals information from supply chain participants.
The current version is CMRT v6.6, released on 17 April 2026 — the 30th version of the template and the 10th release at version 6. Version 6.6 added "Requester Product Number" and "Requester Product Name" fields to the Product List tab, alongside updated conformant smelter lists. The next update is anticipated Spring 2027. The template is an Excel file with several sections:
| CMRT Section | What it captures |
|---|---|
| Declaration Tab | Company info, product scope, whether 3TG is in the product, and whether it is "necessary to the functionality or production" of the product |
| Smelter List Tab | List of smelters/refiners in the supply chain for each 3TG mineral |
| Standard Smelter List | Cross-reference against RMI's conformant smelter list (smelters that have passed independent audits) |
When a brass fitting supplier receives a CMRT request, the correct response is to complete the Declaration Tab indicating that the product does not contain 3TG minerals necessary to the functionality or production of the product, explain that brass is copper-zinc and not in regulatory scope, and return the completed declaration. This does not require completing the Smelter List Tab (which is only relevant when 3TG is present).
Does Brass Fall in Scope? — The Definitive Answer
| Regulatory question | Answer for brass fittings | Basis |
|---|---|---|
| Does brass contain tin (Sn)? | No — Cu+Zn only | EN 12164 CW617N: Cu 57.0–59.0%, Pb 1.6–2.5%, Zn balance. No Sn. |
| Does brass contain tantalum (Ta)? | No | Not specified in any copper or brass alloy standard. |
| Does brass contain tungsten (W)? | No | Not specified in any copper or brass alloy standard. |
| Does brass contain gold (Au)? | No | Not specified. Gold plating on some components may be relevant — see edge cases below. |
| Is Dodd-Frank Section 1502 triggered? | No — for brass body | No 3TG minerals necessary to the functionality or production of the brass fitting. |
| Is EU Regulation 2017/821 triggered? | No | Regulation applies to importers of 3TG minerals/metals — not to brass article importers. |
| Is a CMRT required from Brassland? | Not legally — but Brassland will provide a scope letter | Many SEC-reporting OEMs request it as supply chain policy regardless. We issue written scope determination letters. |
What Brass Actually Contains — Alloy Composition
For absolute clarity, here is the full chemical composition of the principal brass alloys Brassland supplies, per EN 12164 (copper and copper alloys — rod for free machining purposes):
| Alloy | Cu % | Zn % | Pb % | Other elements | 3TG present? |
|---|---|---|---|---|---|
| CW617N (standard) | 57.0–59.0 | Balance | 1.6–2.5 | Fe max 0.3, Ni max 0.3, Al max 0.05, Sn max 0.3 | No 3TG |
| CW602N (DZR) | 61.0–63.0 | Balance | 0.2–0.3 | As 0.02–0.15, Sb max 0.02, Fe max 0.1 | No 3TG |
| CW614N (high-tensile) | 57.0–59.0 | Balance | 2.5–3.5 | Fe max 0.3, Al max 0.05, Mn max 0.5 | No 3TG |
| C101 (ETP copper) | min 99.9 | — | max 0.005 | O 0.02–0.04 | No 3TG |
Note: CW617N alloy may show trace Sn (max 0.3% per specification as a residual element tolerance), but this is a metallurgical impurity tolerance in the copper-zinc alloy — not intentionally added tin and not sourced from cassiterite (the 3TG tin ore). Residual tin in copper alloy produced from recycled scrap does not constitute "use" of tin as a conflict mineral for regulatory purposes.
Edge Cases: When a Brass Assembly Might Be Relevant
While solid brass fittings are outside conflict minerals scope, certain product configurations may bring 3TG into the picture:
Gold-plated brass components
Some brass electrical contacts, connectors or decorative fittings receive gold plating for corrosion resistance or electrical conductivity. Gold is a regulated 3TG mineral. If a brass component has gold plating that is "necessary to the functionality" of the product (e.g. a gold-plated electrical contact in a connector), the gold must be tracked through the conflict minerals supply chain. Brassland does not supply gold-plated components as standard — if you are ordering gold-plated parts, request a separate CMRT for the plating process.
Tin-based solders in assemblies
If a brass fitting is supplied as part of an assembly that includes tin solder (e.g. a pre-soldered fitting kit), the tin solder may trigger conflict minerals analysis. The tin solder — not the brass fitting — would be the subject of the CMRT inquiry. Brassland supplies unmachined fittings without solders — tin from soldering is outside our scope.
Bronze alloys (Cu-Sn)
Bronze is a copper-tin alloy. If your requirement is for bronze (not brass), tin is present as an alloying element. While regulatory guidance varies on whether alloying tin (rather than tin as a functional component) triggers Dodd-Frank, some supply chains request CMRT documentation for bronze components. Brassland's standard range is brass (Cu-Zn), not bronze. Contact us for bronze specifications if required.
Conflict-Affected and High-Risk Areas (CAHRAs)
Both Dodd-Frank and the EU CMR focus on minerals sourced from Conflict-Affected and High-Risk Areas (CAHRAs) — primarily defined as areas governed by armed groups or where there are serious violations of international humanitarian law, widespread violence or fragile post-conflict conditions. The primary region of concern is the DRC and its nine neighbouring countries: Angola, Burundi, Central African Republic, Republic of Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia.
Brass alloy — copper and zinc — is sourced from global mines including those in Chile, Peru, Australia, Zambia, Democratic Republic of Congo (copper), and Australia, India, China (zinc). While the DRC is a significant copper producer, copper itself is not a regulated mineral under conflict minerals legislation. Only tin (cassiterite), tantalum (coltan), tungsten (wolframite) and gold are regulated.
Brassland's alloy feedstock is sourced from Indian and international mills with documented supply chains. Copper used in our alloys originates from smelters that are not in CAHRA regions or that operate under responsible sourcing frameworks.
Brassland's Position & Available Documentation
- Material scope: Brassland manufactures brass (Cu-Zn), copper, and aluminium components. None of these materials contain tin (Sn), tantalum (Ta), tungsten (W), or gold (Au) as intentional alloying elements.
- Regulatory status: Brassland's products are outside the scope of Dodd-Frank Section 1502 (SEC Final Rule 34-67716) and EU Regulation 2017/821 for conflict minerals disclosure purposes.
- CMRT declaration: Brassland can complete the Declaration Tab of CMRT v6.6 (current version, released April 2026) and return it confirming that our products do not contain 3TG minerals necessary to the functionality or production of the products supplied.
- Scope determination letter: Brassland provides a written scope determination letter on company letterhead for customers whose compliance teams require documented confirmation that brass fittings are outside conflict minerals regulatory scope.
- Gold-plating: Brassland does not supply gold-plated components as standard. If ordered, a separate CMRT for the gold plating supply chain will be provided.
- Turnaround: CMRT declarations and scope letters are issued within 2 business days of request.
Frequently Asked Questions
Primary Sources & Further Reading
- 🇺🇸 SEC Final Rule 34-67716 — Conflict Minerals (implementing Dodd-Frank Section 1502)
- 🇺🇸 SEC — Staff Guidance on Conflict Minerals Disclosure
- 🇪🇺 EUR-Lex — EU Conflict Minerals Regulation 2017/821 — Official Text
- 🌐 Responsible Minerals Initiative (RMI) — CMRT v6.6 Template (April 2026), Guidance & Conformant Smelter Lists
- 🌐 RMI — Conflict Minerals Overview and Regulatory Summary
- 🇪🇺 European Commission — EU Conflict Minerals Regulation Guidance
- 📄 Brassland — REACH Compliance Guide (Article 33 and SVHC for brass)
- 📄 Brassland — Certifications & Compliance Documentation
This guide is informational and does not constitute legal advice. Last updated: May 2026. Regulatory scope should be verified against current SEC, ECHA and RMI guidance before making compliance decisions. The regulatory status of conflict minerals requirements continues to evolve — monitor RMI and SEC communications for updates.