Which Minerals Trigger AMRT Requests from OEMs

AMRT requests don’t appear at random. When an OEM asks a supplier to complete AMRT, it’s almost always because specific minerals have been identified as risk-relevant—even if no regulation exists yet.

Suppliers often assume AMRT is a broad sustainability exercise. In reality, it is mineral-driven. Understanding which minerals trigger AMRT—and why—helps suppliers anticipate requests instead of reacting to them.

AMRT Targets Emerging and Critical Minerals

AMRT focuses on minerals that share four characteristics:

1. Strategic importance to electrification and energy transition
2. Concentrated upstream supply, often in geopolitically sensitive regions
3. Limited traceability maturity compared to 3TG or cobalt
4. Growing ESG and policy attention, despite limited formal regulation

These minerals are not selected because they are already regulated. They are selected because OEMs expect future disruption if visibility is delayed.

The Core Minerals That Commonly Trigger AMRT

While OEM-specific scope can vary, AMRT requests are most frequently triggered by the presence or potential presence of the following minerals:

Lithium

Used extensively in batteries, energy storage, and EV systems. Lithium supply chains are highly concentrated and environmentally sensitive, making early visibility a priority.

Nickel

A critical input for high-energy battery chemistries and specialty alloys. Nickel sourcing raises both environmental and labor concerns, especially in newer extraction regions.

Graphite

Essential for battery anodes. Natural graphite sourcing carries environmental and social risk, while synthetic graphite has significant energy intensity.

Manganese

Used in battery cathodes and steel production. Manganese often appears deep in the supply chain, making exposure difficult to assess without structured reporting.

Copper

Fundamental to electrification, wiring, and power systems. Copper demand is rising sharply, and supply constraints are already visible.

Rare Earth Elements

Critical for magnets, motors, and electronics. Rare earth supply chains are highly concentrated and geopolitically sensitive, prompting early OEM scrutiny.

Why These Minerals Are Flagged Before Regulation

OEMs flag these minerals early for practical reasons:

• Supply disruption risk increases faster than regulation cycles
• ESG commitments require evidence of upstream awareness
• Investor scrutiny increasingly focuses on critical mineral exposure
• Customer transparency expectations now extend beyond legal minimums

AMRT allows OEMs to ask a simple question early: “Do we know where these minerals exist in our supply chain?”

The goal is awareness, not perfection.

Mineral Presence vs Mineral Certainty

A critical reason suppliers struggle with AMRT applicability is confusion between:

• mineral presence and
• mineral certainty

AMRT is triggered by possible or likely presence, not proven traceability.

If a product category typically uses lithium, nickel, graphite, or rare earths, OEMs may request AMRT even when:

• the supplier does not control raw material sourcing
• sub-tier visibility is limited
• exact mineral quantities are unknown

This is intentional. AMRT is designed to surface risk signals, not audit-grade proof.

Boundaries Suppliers Must Get Right

Misclassification is one of the fastest ways to lose credibility.

Suppliers must clearly separate:

• 3TG → CMRT
• Cobalt and mica → EMRT
• Other emerging or critical minerals → AMRT

Using AMRT to report cobalt or 3TG does not simplify reporting. It signals confusion about applicability—and usually results in follow-up requests.

Why Suppliers Are Often Surprised by AMRT Requests

Suppliers are frequently caught off guard because:

• minerals are embedded in sub-components
• procurement teams focus on parts, not materials
• regulatory signals have not yet materialized
• material decisions occur upstream of the supplier’s control

AMRT requests do not imply wrongdoing. They indicate that material exposure exists somewhere upstream, and the OEM wants to understand it early.

How OEMs Decide Which Suppliers to Ask

OEMs typically initiate AMRT based on:

• product category risk mapping
• material declarations and BOM analysis
• known battery or electrification content
• ESG and responsible-sourcing segmentation

This means two suppliers selling similar parts may receive different requests—based solely on perceived mineral exposure, not company behavior.

What AMRT Applicability Means for Suppliers

AMRT requests are driven by minerals, not paperwork.

OEMs ask for AMRT when certain materials enter their products—long before laws exist—because waiting for regulation creates risk they cannot manage later.

Suppliers who understand which minerals trigger AMRT can anticipate requests, scope applicability correctly, and respond with clarity rather than confusion.