E1M-AEN Conflict Minerals Declaration
1 Declaration
Alp Lab AB is committed to the responsible sourcing of the "conflict minerals"
— tin, tantalum, tungsten and gold (3TG) — used in the E1M-AEN System-on-Module
family (E1M-AEN301 through E1M-AEN803). Alp Lab does not procure 3TG directly;
its exposure is entirely downstream, through the electronic components in the
module. Alp Lab conducts supply-chain due diligence aligned with the OECD Due
Diligence Guidance and the Responsible Minerals Initiative (RMI), and reports
3TG smelter/refiner data to customers using the RMI Conflict Minerals Reporting
Template (CMRT).
This document is Preliminary. The 3TG content analysis (Section 3) is complete and derived from the released BOM. The smelter list (Section 7) and the customer-facing CMRT XLSX are finalised only once the component-supplier CMRTs in Section 5 are collected and rolled up; until then the smelter declaration is not yet warranted.
2 Scope & Regulatory Framework
This declaration covers the assembled E1M-AEN module, hardware revision R3, as delivered, across all seven MPN variants sharing the common E1M™ BOM. It addresses the conflict- minerals obligations arising under:
| Instrument | Relevance |
|---|---|
| US Dodd-Frank Act §1502 (SEC rule) | 3TG originating in the DRC and adjoining countries; drives customer SEC filings Alp Lab supports as a supplier. |
| EU Conflict Minerals Reg. (EU) 2017/821 | Due-diligence obligations for Union importers of 3TG; supply-chain transparency for downstream users. |
| OECD Due Diligence Guidance | The five-step risk-based framework Alp Lab's diligence is aligned to. |
| RMI CMRT / RMAP | Standardised reporting template (CMRT) and the Responsible Minerals Assurance Process (RMAP) for conformant smelters/refiners. |
3 3TG Content Analysis
The table below maps each conflict mineral to its presence in the E1M-AEN, derived from the released R3 BOM (230 fitted electrical placements, 61 line items, 23 suppliers) and the module's Pb-free SAC assembly process. This determines which supplier CMRTs are material.
| Mineral | Present | Primary source | Where in the module |
|---|---|---|---|
| Tin (Sn) | Yes | SAC solder + terminations | Assembly solder (Sn-Ag-Cu) and the tin-plated terminations of every placement — board-wide |
| Gold (Au) | Yes | Finishes + bond wires | IC bond wires; BGA/QFN/WLCSP package finishes |
| Tungsten (W) | Trace | IC die metallization | Tungsten plugs/vias inside some IC silicon; declared via supplier CMRT |
| Tantalum (Ta) | No | — | Not intentionally present — every capacitor on the module is a ceramic MLCC (the RTC backup capacitor is not fitted in the standard build); the BOM contains no tantalum capacitors |
Key simplification: the E1M-AEN contains no tantalum. Every capacitor fitted on the module is a ceramic MLCC (the RTC backup supercapacitor is not fitted in the standard build), so the tantalum row of the CMRT is declared "not contained" — removing one of the four minerals and its smelter-collection burden entirely. Tin and gold are the materially-present 3TG; tungsten is trace and carried through supplier declarations.
4 Due-Diligence Approach
Because Alp Lab's 3TG exposure is entirely downstream, its diligence consists of cascading the CMRT request to component suppliers and aggregating their declared smelters:
- Collect a current RMI CMRT from each component supplier (Section 5).
- Aggregate the declared smelters/refiners for tin, tungsten and gold across all suppliers into a single module (or company) smelter list.
- Screen each declared smelter against the RMI RMAP conformant-smelter list; flag any non-conformant or unlisted smelter for follow-up.
- Report the result to customers on the RMI CMRT XLSX, re-issued as supplier data and the RMAP list are updated.
5 Supplier CMRT Collection Basis
The module smelter list is a roll-up of the supplier CMRTs below. Suppliers of tantalum-only parts are not applicable (no tantalum in the BOM); every supplier is nonetheless a potential source of tin (terminations) and, for IC/connector suppliers, gold.
| Manufacturer | Material 3TG (this BOM) | CMRT on file |
|---|---|---|
| Texas Instruments | Sn, Au, W | Pending |
| Alif Semiconductor | Sn, Au, W | Request |
| BDE Technology | Sn, Au, W | Request |
| ISSI | Sn, Au, W | Pending |
| Winbond Electronics | Sn, Au, W | Pending |
| Renesas Electronics | Sn, Au, W | Pending |
| onsemi | Sn, Au, W | Pending |
| NXP Semiconductors | Sn, Au, W | Pending |
| Nexperia | Sn, Au, W | Pending |
| Diodes Incorporated | Sn, Au, W | Pending |
| Kinetic Technologies | Sn, Au, W | Pending |
| Murata Electronics | Sn, Au | Pending |
| TDK Corporation | Sn, Au | Pending |
| KEMET | Sn, Au | Pending |
| Yageo | Sn, Au | Pending |
| Samsung Electro-Mechanics | Sn, Au | Pending |
| Taiyo Yuden | Sn, Au | Pending |
| Würth Elektronik | Sn, Au | Pending |
| Delta Electronics / Cyntec | Sn, Au | Pending |
| Micro Crystal AG | Sn, Au | Pending |
| ECS Inc. | Sn, Au | Pending |
| Raltron Electronics | Sn, Au | Pending |
| KYOCERA AVX | Sn, Au | Pending |
Most suppliers in this list publish a current company-level RMI CMRT
on their compliance pages; Request marks the two (Alif, BDE) that need a direct
ask — bundled with the same reliability / materials requests. Source locations
are maintained in the working index supplier-cmrt-index.md.
6 Declaration Level
Two CMRT deliverables are available to customers:
| Level | Description |
|---|---|
| Company (default) | A single Alp Lab AB CMRT declaring 3TG sourcing across all products. Lower maintenance, accepted by most customers, and the recommended default. |
| Product | A CMRT scoped specifically to the E1M-AEN smelter roll-up. Available on request where a customer's due-diligence requires product-level granularity. |
7 Smelter / Refiner List
Pending supplier CMRT collection. The aggregated tin, tungsten and gold smelter/refiner list — with each entry's RMI Standard Smelter ID and RMAP conformance status — is populated here once the supplier CMRTs in Section 5 are received. The tantalum section is declared not contained.
8 Limitations
- Downstream declaration. Alp Lab does not source 3TG directly; the smelter list is only as complete and current as the supplier CMRTs it aggregates.
- Per-revision / periodic re-issue. Re-issued on a BOM change and periodically as suppliers publish updated CMRTs and the RMAP conformant list changes.
- XLSX is the formal artifact. This document is the companion statement; the machine-readable RMI CMRT workbook is the deliverable customers ingest.
9 Authorisation
Signed for and on behalf of Alp Lab AB:
Signature: ______________________________
Name: ______________________________
Title: ______________________________
Date: ______________________________
Place: ______________________________
10 Revision History
| Revision | Changes | Date |
|---|---|---|
| 0.1 |
| June 2026 |
| 0.2 |
| October 2026 |
| 0.3 |
| October 2026 |