Downstream Assessment Program

The Downstream Assessment Program (DAP) is a minerals agnostic (inclusive of any metal/mineral within a company’s operations) assessment for downstream companies to validate responsible sourcing practices as aligned with the OECD Due Diligence Guidance for Responsible Mineral Supply Chains from Conflict-Affected and High-Risk Areas. When participating in DAP, Companies should indicate all the minerals in scope of its operations. Companies can choose to include specific minerals targeted for DAP assessment (for example (3TG, Cobalt, Nickel, Copper, etc.) or all the minerals in is scope.

The RMI launched the DAP in 2016 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). The DAP is applicable to any metal/mineral within a company’s operations. The DAP portfolio was updated in 2024 with clarified requirements and additional guidance for companies and assessment firms utilizing the DAP. For more information, please see the statement on the RMI News page here.

The Downstream Assessment Program is designed to:

Provide validation for customer and investor requirements to demonstrate that companies responsible sourcing practices are aligned to the OECD Due Diligence Guidance for Responsible Minerals Supply Chains
Provide validated information about companies' due diligence practices across mineral and metal value chains,
Support company compliance with the regulatory requirements globally, such as the EU Responsible Minerals Regulation (EU CMR 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, as well as EU Battery Regulation (latter, in combination with the RMI ESG assessment).
Support companies 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.

In addition to providing companies with validation of OECD-aligned sourcing practices, DAP:

Provides public listing on the RMI’s DAP Participant List for the companies that have successfully completed a downstream program
Helps Companies verify Mineral Reporting Template survey results (such as CMRT, EMRT, PRT) and know their suppliers
Supports Companies risk identification and mitigation

DAP List

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

What is the DAP Program Scope?

Mineral Scope: All minerals

Validity Timeline: 2 years

Eligibility: Downstream Processors, Downstream Traders, Manufacturers (more information below)

Sourcing:

100% recycled materials and/or
From RMAP conformant facilities
- For 3TG and Cobalt: Company sources solely from RMAP or equivalent (cross-recognized) conformant smelters, refiners, and upstream processors (pinch-point)
- For all other minerals and metals: Company sources solely from RMAP Eligible smelters, refiners, upstream processors (pinch-point) that have documented commitment to become conformant to the RMAP or equivalent (cross-recognized) Standard by the time of the company’s next downstream assessment (2 years)

Assessment Level: Facility specific, so each company facility has to be assessed that is interested in undergoing DAP, unless all processes/procedures/material intake and due diligence are centralized at the company headquarters, then sampling of sites (rather than assessments of every single site) in addition to assessment at the headquarters may be permitted

Who is Eligible?

Companies that fall within the following categories are eligible to participate in this 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.
Downstream Processor: The company procures mineral or metal products to transform, process or otherwise treat the material and doesn’t have the capability to process primary materials. Downstream Processors do not have the capability to perform smelting, refining, or upstream processing functions, and do not meet the definition of a “smelter” or “refiner” according to the applicable RMAP Standard
Downstream 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.
- 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.
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
Other companies operating downstream of smelters and refiners: Please contact RMIassessment@responsiblebusiness.org if you are interested in participating in the DAP program.

Program Documents

DAP Criteria (ENG) contain requirements for participating companies and serve as the standard for the Downstream Assessment Program
DAP Assessment Procedure and Guidance (ENG) provides detailed information for companies wishing to undergo an assessment and ensures the consistent implementation of the assessment process; it should be used for assessment preparation for assessors and companies assessed under DAP
DAP Assessment Tool contains DAP criteria questions, assessment overview and findings and is only available on RBA-online (in 2024 the RMI added newly developed data points and guidance on DAP requirements for assessors to the tool)
RBA Assessment Agreement for Exchange of Confidential Information and Auditee Participation must be reviewed and completed by the auditee prior to assessment
Due Diligence Check List (CHI | ENG | JPN | KOR)
Company Identification Questionnaire (CIQ) (CHI | ENG) - CIQ for 3TG, Cobalt, and Downstream Assessment Program (DAP)
Pre-Assessment Checklist gathers basic information to determine the scope of the assessment and identify the correct location(s) for the auditor to visit
DAP Assessment Report contains full results and details of the assessment, designed for internal company use, or if company choses to, it may also share confidentially with their clients.
DAP Assessment Summary Report summarizes the assessment process and results, with confidential information removed, it is 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
Downstream Company Due Diligence Guidance: How Downstream Companies Can Use RMI’s Tools To Support Their Due Diligence.

To request a downstream assessment or learn more, please contact rmiassessment@responsiblebusiness.org.

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, refiners and upstream processors 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 (MRTs)

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