Downstream Assessment Program

In 2016 the RMI launched its Downstream Assessment Program to meet the growing demand for validation of sourcing practices of companies in the mineral and metal industries that are not eligible for the Responsible Minerals Assurance Process (RMAP) because they do not meet the definition of a smelter or refiner. The Downstream Assessment Program is minerals-agnostic and therefore inclusive of any metal/mineral within a company’s operations.

Facilities participating in the Downstream Assessment Program have often been asked by their customers to demonstrate that their responsible sourcing practices are aligned with the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas, and to provide validated information about their due diligence activities. The Downstream Assessment Program is designed to provide this validation for customer requirements across mineral and metal value chains, and to meet the European Union Responsible Minerals Regulation (EU Regulation 2017/821) requirements for EU importers of tin, tantalum, tungsten and gold (3TG) that do not meet the definition of a smelter or refiner.

The table below includes all facilities that have successfully completed a downstream assessment:

Who is Eligible?

Companies that fall within the following categories are eligible to participate in this program:

  • Union Importer: Any natural or legal person declaring minerals or metals for release for free circulation within the meaning of Article 201 of Regulation (EU) No. 952/2013 of the European Parliament and of the Council (1) or any natural or legal person on whose behalf such declaration is made, as indicated in data elements 3/15 and 3/16 in accordance with Annex B to Commission Delegated Regulation (EU) 2015/2446 (2).
    • Regulatory requirements pertaining to union importers of minerals are included in the Regulation (EU) 2017/821 of the European Parliament and of the Council of 17 May 2017 laying down supply chain due diligence obligations for Union importers of tin, tantalum and tungsten, their ores, and gold originating from conflict-affected and high-risk areas.
    • For more information about how RMI and RBA can support you EU regulatory preparedness visit: www.responsiblemineralsinitiative.org/media/docs/RMI_RBA_EU_CMR_Reg_Preparedness_2020_updated.pdf
    • NOTE: Any smelter site belonging to a company that owns a primary smelter is also considered to be a primary smelter and eligible for the RMAP. These facilities are not eligible for the Downstream Assessment Program.
  • Manufacturing/Assembly: A manufacturer refers to a company that makes products and where the metal is added into a product and/or a product containing metals is further processed or assembled.
  • Processor: The company procures mineral or metal products to transform, process or otherwise treat the material. Processors do not have the capability to perform smelting or refining processes, and do not meet the definition of a “smelter” or “refiner” according to the applicable RMAP Standard.
  • Trader: An individual or company that buys and sells mineral-containing substances or products without altering their physical or chemical states. This may include mineral, metal or product importers or exporters.
  • Other companies operating downstream of smelters and refiners: Please contact RMI if you are interested in participating in the DAP program.

Program Documents

  • Pre-Assessment Checklist gathers basic information to determine the scope of the assessment and identify the correct location(s) for the auditor to visit
  • Assessment Tool contains conformance requirements for participating companies and serves as the standard for the Downstream Assessment Program, also ensures the consistent implementation of the assessment process
  • Assessment Report (Manufacturers | Processors | Traders ) containing full results and details of the assessment, designed for internal company use
  • Assessment Summary Report ( Manufacturers | Processors | Traders ) summarizing the assessment process and results, confidential information removed, designed to be shared publicly or with customers
  • Corrective Action Plan based on a standardized scoring matrix defining risk levels, type of non-compliances, timeframes for corrective actions and basic corrective actions to be taken
  • Agenda Template (ENG | CHI) to provide a generic layout of assessment activities
  • Assessment Guidance (ENG | CHIprovides detailed information for companies wishing to undergo an assessment and should be used for assessment preparation

To request a downstream assessment or learn more, please contact Catherine Tyson.

What is Assessed?

The assessment is based on the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas.

The assessment follows the ISO19011:2011 standard for management systems assessments to assess a company’s processes to:

  • Determine the products and suppliers included in the effort to identify smelters and refiners in the supply chain, to confirm that the scope is correctly defined
  • Select, approve and monitor suppliers of minerals and metals or products containing minerals and metals
  • Monitor transactions of minerals and metals received and to maintain adequate documentation to confirm the origin of minerals and metals or mineral and metal-containing products
  • Identify, assess, and manage risks in the minerals and metals supply chains in line with the OECD Due Diligence Guidance
  • Develop and review information on the company’s supply chain via relevant reporting tools, including the RMI’s Minerals Reporting Templates

What are the benefits of participating?

  • Offers independent third-party assurance for companies importing 3TG-containing products into the EU in light of the EU Regulation 2017/821, which requires mandatory due diligence for importers of minerals and metals of 3TG
  • Supports company’s responsible mineral/metal sourcing efforts in all commodity supply chains
  • Consolidates reporting requirements within the downstream by streamlining the assessment and reporting processes
  • External review of the company's supply chain due diligence program, which provides an assessment of:
    • The scope of the program;
    • The design and effectiveness of due diligence activities;
    • The accuracy of reporting to customers;
    • Alignment with the OECD Due Diligence Guidance
  • Full Assessment Report, including all information pertaining to the assessment
  • Assessment Summary Report that is made public (confidential information redacted)
  • Public listing via an online and publicly accessible RMI registry, which lists companies that meet the Downstream Assessment Program requirements
  • Demonstrate year-over-year improvement of due diligence for your company