Südkupfer supports its customers in addressing these growing requirements by providing the Extended Minerals Reporting Template (EMRT). This widely established industry tool enables a standardized exchange of supply chain information and contributes to greater transparency within complex value chains.
Although we are currently not legally required to provide such information, we consider supporting our customers in creating transparency to be an important element of responsible and forward-looking business relationships.
Conflict minerals: What role does copper play?
In discussions about supply chain transparency, the term “conflict minerals” is often used. In regulatory contexts, this primarily refers to tin, tantalum, tungsten and gold (3TG), whose extraction in certain regions has been linked to the financing of armed conflicts or human rights violations.
Copper may also originate from conflict-affected or high-risk areas. However, unlike the 3TG metals, there is currently no specific EU due diligence regulation for copper imports. The use of EMRT in the copper context therefore does not serve to fulfill regulatory conflict minerals requirements but rather aims to promote transparency and support standard industry communication within supply chains.
What is EMRT?
The Extended Minerals Reporting Template was developed by the Responsible Minerals Initiative and serves as a standardized format for sharing supply chain information related to minerals.
In addition to information on smelters and refiners, the template includes standardized questions on corporate policies, supplier requirements, risk assessment and measures taken to address identified risks. These inputs allow an assessment of supply chain processes but do not constitute proof of origin or confirmation of legal compliance.
From our perspective, it is important to clearly classify the purpose of the EMRT:
The EMRT is not a certification system and does not provide physical traceability back to the mine. Instead, it is a communication tool that consolidates available information from upstream supply chains in a structured format. This is precisely how Südkupfer uses the template.
Although the template was originally developed in the context of conflict-related mineral transparency, its application in the copper sector today is primarily driven by market requirements, standardization and customer communication rather than by regulatory conflict mineral classification.
EMRT Version 2.1 – Expansion and Growing Relevance
The currently used Version 2.1 differs significantly in its practical relevance from earlier versions of the template. While the original versions mainly focused on a limited number of critical minerals, the scope has gradually expanded.
With Version 2.0, introduced in 2025, several important developments became relevant:
- inclusion of additional strategic metals such as copper
- stronger alignment with industrial transparency requirements
- enhanced structure for reporting smelter information
- improved compatibility with regulatory developments (e.g. supply chain requirements and ESG reporting)
For a trading company in the copper market, this means that the EMRT is now requested much more frequently by customers than in the past and has gained significantly in practical relevance.

Südkupfer’s Role in This Process
Within the metal supply chain, Südkupfer operates as a trading company. We do not engage in mining, smelting or refining activities and therefore rely on information provided by our upstream partners.
Our role is to make this information available in a format that is usable and compatible with our customers’ reporting requirements. In this context, the EMRT has proven to be a practical and widely accepted standard.
At Südkupfer, the template is prepared based on available supplier information and updated on a regular basis. It mainly includes information on relevant smelters and refiners within the upstream value chain.
The EMRT serves as a standardized information basis for all stakeholders. We do not prepare customer-specific versions of the template.
Practical Realities of Global Supply Chains
When using the EMRT, it is important to consider typical characteristics of the metal industry:
- refineries process raw materials from multiple sources
- materials are further processed and combined along the supply chain
- trading flows are aggregated and distributed internationally
- physical traceability to the mine is not standard practice in the trading segment
Therefore, the listing of a smelter in the EMRT does not indicate the origin of individual material shipments but reflects the available information within upstream supply chain structures.
Against this background, it is also useful to consider how material flows actually function in industrial production processes.
Material Flows and the “Material Allocation” Model
In discussions with customers, we occasionally observe that the functioning of industrial material flows and so-called material allocation systems is not always fully understood.
In the metals industry, copper quantities are often managed on metal accounts rather than physically transported between locations. Material quantities are recorded in accounts and allocated or released within the supply chain depending on production and delivery requirements.
In practical terms, this means that the copper actually used in a specific intermediate product does not necessarily originate from a particular physical delivery but from the available material pool of the processing company.

During melting, casting and manufacturing processes, material streams are regularly combined, remelted or used flexibly according to production needs. Consequently, a batch-specific allocation of the material to individual components or end products is generally not feasible.
We can therefore provide transparency regarding our own sourcing processes and upstream supply chain information. However, physical traceability within components or assemblies depends primarily on the production and supply structures of our customers and their direct suppliers.
In some cases, the impression arises that the copper supplied by us is used directly in the production of specific intermediate products. In reality, material usage in industrial processes is flexible and depends on production processes, quality requirements and material availability.
For a detailed traceability of physical material flows, we therefore recommend also involving the direct suppliers of the respective components.
Procurement Logic and Transparency
In practice, we observe that companies often focus their transparency and due diligence requests on suppliers with the highest purchasing volumes.
Since the material value of copper cathodes represents a significant share of total procurement costs, traders and metal suppliers naturally receive particular attention in such requests.
However, the actual processing of copper takes place in downstream manufacturing stages. Processing and conversion costs incurred by direct suppliers of our customers are often below internal review thresholds and therefore may not always be examined with the same level of detail.
For comprehensive transparency across the value chain, it is therefore essential to also include these direct suppliers. This is where the physical processing of the material takes place and where key information regarding the use of copper within components and assemblies arises.
While we can provide transparency regarding upstream supply chain information, full traceability within finished products can only be achieved when all relevant process stages are considered.
In our experience, a holistic approach to supply chain transparency produces far more robust results than focusing solely on suppliers with the highest material value.

Added Value for Our Customers
Providing the EMRT supports our customers in particular with:
- their own reporting obligations
- supply chain risk assessments
- internal compliance and risk management processes
- ESG documentation
- standardized communication with their own downstream partners
Our approach is deliberately pragmatic. We aim to provide transparent information within the scope of our position in the supply chain without creating expectations of physical traceability that are not realistic within the industry.
Outlook
The importance of structured supply chain information will continue to grow, not only due to regulatory developments but also because of increasing market expectations.
Version 2.1 of the EMRT already reflects the growing relevance of strategic industrial metals such as copper within transparency frameworks.
Südkupfer continuously monitors these developments and adapts its information processes accordingly in order to continue providing customers with reliable and practical data for their supply chain transparency requirements.
For further information, please do not hesitate to contact us.













