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Most AMRT submissions fail for one reason: the wrong answers are being given to the right questions.
Teams familiar with CMRT or REACH often approach AMRT as if it requires the same level of precision and proof. That instinct is understandable—and incorrect. AMRT declaration questions are designed to surface risk awareness and maturity, not audit-grade traceability.
This guide explains how to approach AMRT declaration questions correctly, what data is actually expected, and how to avoid the most common credibility traps.
What the AMRT Declaration Section Is Designed to Do
AMRT declaration questions are not a checklist for compliance. They exist to determine whether a supplier:
- recognises the potential presence of emerging or critical minerals
- understands where risk may exist in products or materials
- has early-stage due-diligence thinking in place
- can describe policies and processes relevant to mineral risk
In short, the declaration section evaluates awareness and intent, not proof of control.
Why AMRT Declaration Logic Differs from CMRT
CMRT declaration questions are designed to support regulatory determinations:
- confirmed presence of 3TG
- identification of upstream smelters
- audit program alignment
AMRT declaration questions serve a different purpose:
- early risk signalling
- acknowledgment of limited visibility
- disclosure of due-diligence maturity
Applying CMRT logic to AMRT responses usually leads to:
- overconfident statements
- invented certainty
- follow-up questions from customers
The goal in AMRT is credibility, not completeness.
How to Interpret “Yes,” “No,” and “Unknown” Correctly
One of the most common AMRT mistakes is misunderstanding response options.
“Yes” in AMRT
Use “Yes” when:
- the mineral is present or likely present
- product logic supports that conclusion
- internal teams recognise the exposure
“Yes” does not require full upstream mapping.
“No” in AMRT
Use “No” only when:
- product and material logic supports exclusion
- the mineral is genuinely not used
- the statement can be defended if questioned
Blanket “No” responses without product reasoning often trigger follow-up.
“Unknown” in AMRT
“Unknown” is acceptable when:
- sub-tier visibility is limited
- supplier engagement is ongoing
- the uncertainty is explained
“Unknown” becomes a problem only when:
- it is used everywhere
- it is repeated year after year
- no improvement path is described
AMRT accepts uncertainty. It does not accept avoidance.
What Supporting Context Actually Matters
AMRT does not require document uploads, but declaration answers should be supported by logical context, such as:
- how products are typically manufactured
- which materials are likely used
- where supplier visibility ends
- what engagement or review steps exist
Policies and codes of conduct add value only when they connect to mineral awareness. Generic ESG language without product linkage rarely helps.
Common Declaration Errors That Cause Rework
The following issues are responsible for most AMRT follow-ups:
- copying CMRT declaration language into AMRT
- claiming full upstream certainty without evidence
- using “not applicable” to avoid mineral questions
- denying mineral presence despite product category indicators
- inconsistent answers across business units or years
These errors signal misalignment, not immaturity.
How Reviewers Read AMRT Declarations
AMRT reviewers are not looking for perfection. They are looking for:
- internal consistency
- alignment between product logic and answers
- acknowledgement of known limitations
- signs of improvement over time
A cautious, well-reasoned declaration is typically viewed more favorably than an overconfident one that cannot be explained.
How to Approach AMRT Declarations the Right Way
Before answering AMRT declaration questions, teams should align internally on:
- which product categories are in scope
- which minerals are plausible based on design
- where visibility is strong vs weak
- how uncertainty will be described
AMRT declarations should be deliberate, not reactive.
What AMRT Data Expectations Mean for Suppliers
AMRT declarations are not a test of control. They are a test of awareness and honesty.
Suppliers that succeed with AMRT:
- answer declaration questions conservatively
- explain uncertainty instead of hiding it
- avoid CMRT-style overprecision
- treat declarations as evolving signals
Filling the AMRT correctly is less about having perfect data—and more about knowing what you know, and being clear about what you don’t.