Dodd-Frank §1502 · EU Reg 2017/821 · RMI CMRT

Conflict Minerals (CMRT)

Why brass falls outside the 3TG conflict-minerals scope — and the CMRT and scope-determination documentation we provide.

At a glance

Conflict minerals and brass, summarised for supply-chain teams.
Framework
US Dodd-Frank §1502 (SEC Form SD) and the EU Conflict Minerals Regulation (EU) 2017/821.
3TG minerals
Tin, tantalum, tungsten and gold — the regulated "conflict minerals".
Brass composition
Copper and zinc (plus lead or silicon) — none of the 3TG minerals.
Trace tin
Only present at trace level in certain special grades; not intentionally sourced 3TG.
From Brassland
Completed RMI CMRT and a written scope-determination letter on request.
Background

What is a CMRT?

The Conflict Minerals Reporting Template (CMRT) is a free, standardised form from the Responsible Minerals Initiative (RMI). It is used to report whether products contain tin, tantalum, tungsten or gold (3TG) and, if so, the smelters and refiners and the country of origin — with the focus on minerals sourced from the Democratic Republic of the Congo and adjoining conflict-affected and high-risk areas.

The reporting obligations come from two main frameworks: in the US, Section 1502 of the Dodd-Frank Act requires SEC-listed companies to file a Form SD where 3TG are necessary to the functionality or production of their products; in the EU, Regulation (EU) 2017/821 places due-diligence duties on importers of 3TG. Both turn on the presence of 3TG.

Scope

Brass and the 3TG minerals

Standard brass alloys (CW617N, CW602N, CW724R) are composed of copper, zinc, lead and silicon — none of which are 3TG minerals. Brass and copper products are therefore generally outside the scope of conflict-minerals reporting.

3TG mineralPresent in brass?
Tin (Sn)No — trace only in certain special grades
Tantalum (Ta)No
Tungsten (W)No
Gold (Au)No
Documentation

What we provide

For customers who must demonstrate conflict-minerals due diligence to their own supply chain — for example SEC-listed OEMs supplying automotive or electronics programs — Brassland provides a written scope-determination letter confirming that our brass and copper products fall outside the 3TG scope and that no conflict-minerals filing is required for them. Where a customer's system requires it, we can also supply a completed RMI CMRT for your records. See our materials library for the composition of each alloy.

How to comply

Getting CMRT documentation

01 · TELL US

Your reporting need

Let us know whether you need a scope-determination letter, a completed CMRT, or both for your due-diligence system.

02 · WE CONFIRM

Scope determination

We confirm in writing that the brass or copper grades you buy contain no 3TG minerals.

03 · YOU RECEIVE

CMRT & letter

You receive the documentation to attach to your own conflict-minerals reporting — same business day on request.

FAQ

Common questions

What minerals do the conflict-minerals rules cover?
The rules cover tin, tantalum, tungsten and gold — known collectively as 3TG. Brass is an alloy of copper and zinc and contains none of these 3TG minerals.
Are brass fittings in scope for conflict minerals?
Brass is an alloy of copper and zinc, neither of which is a 3TG mineral (tin, tantalum, tungsten or gold). Standard brass is therefore generally outside 3TG scope; the only 3TG to assess is trace tin in certain bronzes or solders.
Can Brassland provide a CMRT?
Yes. We can supply a completed Conflict Minerals Reporting Template (the RMI CMRT) and a written scope-determination letter on request to support your due-diligence reporting.
Is your supply chain conflict-free?
Our copper and zinc feedstock is sourced from established suppliers, and we provide a CMRT and declarations so customers can complete their own conflict-minerals due diligence. Contact us for documentation.
Sources & References

Verify against the primary source

The regulatory data summarised on this page is cross-referenced against the publishers below. Always confirm requirements against the current published text before relying on this summary.

Last reviewed: June 2026 · maintained by the Brassland compliance team. Conflict-minerals frameworks are updated periodically; the official RMI, SEC and EU texts always prevail — verify the current requirements at the source. General guidance, not legal advice.

Need conflict-minerals documentation?

CMRT, scope-determination letters and material data — typically available the same business day.