Key Takeaways

📌 CMRT 6.6 (released April 17, 2026) and the unbranded CMRT 6.6.2 are both Responsible Minerals Initiative (RMI) 6.6-family templates, and RMI states they are functionally identical.

📄 The unbranded 6.6.2 is RMI’s own release, not a third-party or modified file.

⚠️ A supplier who completed 6.6.1 or 6.6.2 has not submitted anything invalid and does not need to redo it.

📊 Judge a CMRT by the completeness of its declaration and smelter data, not by its version label.

🔗 Large manufacturers receive CMRTs on mixed version numbers because suppliers download the template from different sources.

🤖 A content-based acceptance policy keeps Form SD and EU Conflict Minerals Regulation reporting on schedule.

Procurement and responsible-sourcing teams at large manufacturers collect conflict minerals declarations from hundreds or thousands of suppliers each reporting cycle. Those files do not all carry the same version number, and the CMRT 6.6 vs 6.6.2 question has become a frequent source of confusion in supplier-quality reviews. The short answer: both are current RMI templates, and rejecting a complete declaration over its version string delays reporting without improving data quality.

This article explains what each version is, why RMI publishes more than one, how the versions relate to US and EU reporting obligations, and how manufacturers should set a defensible acceptance policy. If you want to pressure-test your own acceptance rules before your next filing, you can request a compliance review.

What the CMRT Is and Why Version Numbers Vary

The Conflict Minerals Reporting Template (CMRT) is a free, standardized RMI template used to pass tin, tantalum, tungsten, and gold (3TG) country-of-origin and smelter or refiner information through the supply chain. It also helps identify new smelters and refiners that may undergo RMI’s Responsible Minerals Assurance Process (RMAP). The CMRT is central to 3TG due diligence, as explained in the Ultimate Guide to Conflict Minerals Compliance.

Suppliers download the CMRT from different places: RMI directly, customer portals, compliance vendors, and unbranded copies embedded in other tools. The same underlying template therefore reaches you on different revision numbers. That variation is expected and, in most cases, not a problem. What supports your filing is the content of the declaration, not the label on the Declaration sheet.

The Official Template: CMRT 6.6 (April 17, 2026)

CMRT 6.6 is the current official version, released by RMI on April 17, 2026. It is the 30th release of the template and the 10th within the version 6 series, according to RMI-aligned reporting. RMI recommends using the current version for the reporting year, while earlier version-6 CMRTs generally remain valid and companies are encouraged to adopt the latest release for accuracy and defensibility.

The main changes introduced in 6.6 were targeted refinements rather than a change in scope:

• New Product List fields added “Requester Product Number” and “Requester Product Name” for clearer product-level identification.

• IPC-1755 alignment improved interoperability with the material declaration standard maintained by the Global Electronics Association (formerly IPC).

• Updated ISO short names for country and state or province references.

• Refreshed Smelter Reference List and Standard Smelter List with the latest RMI facility data.

RMI has indicated the next CMRT version is anticipated in Spring 2027. The current file and completion guide are always available on the official RMI CMRT page. The product-level additions in 6.6 also matter for teams that connect declarations to specific parts through BOM-level compliance tracking.

What Is CMRT 6.6.2? RMI’s Own Unbranded Version

CMRT 6.6.2 is RMI’s own unbranded version of 6.6. An unbranded, or white-label, CMRT is the same RMI template with the RMI name and logo removed so a company or tool can present it under its own identity. RMI publishes it on purpose. It is not modified, and it is not a third-party file. Based on RMI’s own guidance, CMRT 6.6 and 6.6.2 are functionally identical.

On the unbranded file, the Declaration sheet carries the 6.6.2 revision stamp, the Instructions reference a generic issuer placeholder rather than RMI, and the standalone revision-history sheet is omitted. None of those differences change the data you collect. The declaration questions, the Product List fields, and the smelter-list structure are the same as 6.6.

CMRT 6.6 vs 6.6.2: Side by Side

The only differences between the two files are branding, the revision number, and the date. Everything that supports your filing is identical.

What About CMRT 6.6.1

CMRT 6.6.1 is also part of the 6.6 family. It carries the same fields, the same declaration questions, and the same smelter-list structure, and RMI subsequently updated it to 6.6.2. In practice it is functionally equivalent to 6.6 and 6.6.2.

A supplier who completed a 6.6.1 file does not need to redo it. The data required for US SEC Form SD or EU Conflict Minerals Regulation purposes is present and valid. Treating a completed 6.6.1 as a rejected submission creates unnecessary back-and-forth with suppliers that have already done the work, which is exactly the friction that streamlined supplier documentation is meant to remove.

Why This Matters for Your Reporting Obligations

Conflict minerals due diligence is not an internal formality. The CMRT supports several legal reporting regimes, so an avoidable version dispute can hold up a filing.

For companies filing Form SD, the version used to collect supplier data is reflected in the Reasonable Country of Origin Inquiry. Using the current template demonstrates active due diligence. The practical risk is the opposite: a declaration that passes a basic check only because it was validated against an obsolete structure. The defensible position is to confirm the file is a current, functionally equivalent RMI template with complete content, then judge that content against RMI’s current smelter data.

You can verify the EU and US positions directly through the EU Conflict Minerals Regulation 2017/821 on EUR-Lex, the SEC conflict minerals rule and Form SD, and the OECD Due Diligence Guidance.

Should Manufacturers Accept a Differently-Numbered CMRT

Yes, when the file is a current, functionally-equivalent RMI template with complete content. The defensible test is content, not the version string. A declaration is usable when:

✓ The template structure matches RMI’s 6.6 layout.

✓ All standard due-diligence and product-level declaration questions are answered.

✓ Smelter entries match RMI’s current Standard Smelter List by CID number.

✓ Scope, effective date, product list, and authorisation fields are present.

Rejecting a file simply because it does not say “6.6” wastes review cycles and can delay a filing over a label. This matters most for manufacturers with deep supply bases in electronics manufacturing and automotive manufacturing, where thousands of CMRTs arrive each cycle on a mix of version numbers. A clear, content-based acceptance policy keeps supplier and contractor management focused on data quality rather than version policing.

How Certivo Helps Manufacturers Handle Different CMRT Versions

Certivo validates a CMRT by its content, not its version label. Because 6.6, 6.6.1, and the unbranded 6.6.2 are all 6.6-family files with the same fields, declaration questions, and smelter-list structure, Certivo treats them the same way, so mixed version numbers from suppliers do not block a manufacturer’s reporting.

When a CMRT is received, CORA-powered regulatory intelligence checks that the template structure matches RMI’s 6.6 layout, that the declaration questions are answered, that smelter entries match RMI’s current Standard Smelter List by CID number, and that scope, effective date, product list, and authorisation fields are present. Where a declaration is incomplete or a smelter entry cannot be matched, those gaps are surfaced for the compliance team to review before the file is relied on for reporting.

For manufacturers, mixed version labels do not stall the filing. For suppliers, a completed 6.6.1 does not need redoing, and new declarations should start from RMI’s official current template. Teams managing this at scale can keep records audit-ready across frameworks without rebuilding a declaration every time a version number changes.

Practical Takeaways for Manufacturers and Suppliers

🏭 For suppliers: Complete the declaration accurately. If you already finished a 6.6.1 or 6.6.2 file, you do not need to redo it on 6.6. For new declarations, start from RMI’s official current template.

📄 For manufacturers: Base your acceptance policy on content completeness and smelter matching, not on the version string. Accept current, functionally-equivalent 6.6-family templates (6.6, 6.6.1, 6.6.2), and verify older files against the current structure before relying on them.

🔗 For both: Always download the current template from the official RMI CMRT page before issuing a questionnaire, and manage conflict minerals as an ongoing data exercise rather than an annual scramble, as covered in AI tools for compliance management.

If your team is spending review cycles reconciling version numbers instead of improving declaration quality, speak with a compliance specialist to see how content-based validation fits your reporting workflow.