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Lumentum Holdings Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2024
Introduction
Lumentum Holdings Inc. (“we”, “our”, “Lumentum” or the “Company”) is an industry-leading provider of optical and photonic products defined by revenue and market share addressing a range of end market applications including Optical Communications (“OpComms”) and Commercial Lasers (“Lasers”) for manufacturing, inspection and life-science applications. We seek to use our core optical and photonic technology and our volume manufacturing capability to expand into attractive emerging markets that benefit from advantages that optical or photonics-based solutions provide, including 3D sensing for consumer electronics and diode light sources for a variety of consumer and industrial applications. The majority of our customers tend to be original equipment manufacturers (“OEMs”) that incorporate our products into their products which then address end-market applications. For example, we sell fiber optic components that our network equipment manufacturer (“NEM”) customers assemble into communications networking systems, which they sell to network service providers or enterprises with their own networks. Similarly, many of our customers for our Lasers products incorporate our products into tools they produce, which are used for manufacturing processes by their customers. For 3D sensing, we sell diode lasers to manufacturers of consumer electronics products for mobile, personal computing, and gaming who then integrate our devices within their products, for eventual resale to consumers and also into other industrial applications. Lumentum has a global marketing and sales footprint that enables us to address global market opportunities for our products. Lumentum has manufacturing capabilities and facilities in North America, Asia-Pacific, and Europe, with employees engaged in research and development, administration, manufacturing, support and sales and marketing activities. For more information, please refer to Lumentum’s Annual Report on Form 10-K for the fiscal year ended June 29, 2024, filed with the U.S. Securities and Exchange Commission (“SEC”) on August 21, 2024.
This Report has been prepared in accordance with the requirements of Rule 13p-1 (the “Rule”) and Form SD promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. This Report relates to the process undertaken by Lumentum to exercise due diligence on the source and chain of custody of cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “Conflict Minerals”) contained in Lumentum products that were manufactured, or contracted to be manufactured, during the calendar year 2024. Third-party products that Lumentum sells but that it does not manufacture or contract to manufacture are outside the scope of this Report. This Report can be found on our website at www.lumentum.com/investors.
Executive Summary
Lumentum reviewed its supplier base to determine which suppliers were supplying Lumentum with parts or materials that were necessary to the functionality or production of the products we manufactured in calendar year 2024 and contained Conflict Minerals. We then contacted these identified suppliers to complete the Conflict Minerals Reporting Template (‘CMRT”) as part of our reasonable country of origin inquiry (“RCOI”). In connection with the CMRT, these suppliers generally provided us with a list of smelter or refiner names (collectively, “smelters”) that may have provided the Conflict Minerals in the parts or materials provided to us. We do not have a direct contractual or business relationship with these smelters, thus we worked closely with our suppliers-in-scope for our RCOI process. Through the RCOI process, 329 unique smelter entities were identified. Of these 329 smelters, 41 were identified as sourcing (or there was a reason to believe they may be sourcing) from the Democratic Republic of Congo (the “DRC”) or surrounding countries (collectively, the “Covered Countries”). Lumentum’s due diligence review indicates that 41 of the 41 smelters were found to be conformant to a Responsible Minerals Assurance Process (RMAP) as of December 31, 2024. However, one (1) smelter, for which there is reason to believe it may be sourcing from Covered Countries, was no longer conformant as of January 2025 and therefore, is subject to Lumentum’s risk mitigation process described below.
Design of Due Diligence
Lumentum designed its due diligence measures to conform to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (the “OECD Guidance”). The OECD Guidance sets forth five steps for supply chain due diligence. There is significant overlap between our reasonable country of origin inquiry (“RCOI”) efforts and our due diligence measures performed, both of which are described below.
Management Systems
Lumentum has established a management system for Conflict Minerals. This included the creation of a Conflict Minerals Team comprised of senior leaders from functional areas of Lumentum impacted by Conflict Minerals. This team was created to support supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program. We have a grievance mechanism through which our employees and suppliers can report a violation of our policies and maintain an e-mail address conflictminerals@lumentum.com for suppliers and employees to report violations, ask questions and voice concerns. We established a system of controls over our mineral supply chain, including the RCOI and due diligence procedures described below. All relevant Conflict Minerals data is kept in our internal database system.
Reasonable Country of Origin Inquiry
Lumentum conducted a RCOI that was designed to include all suppliers and original manufacturers that supplied parts or materials that contained Conflict Minerals and were necessary to the functionality or production of the products we manufactured in calendar year 2024. We conducted the RCOI and retained a third-party consulting firm to assist with the due diligence processes. As part of our RCOI, we contacted approximately 199 in-scope suppliers, representing those most relevant based on spend. Each direct supplier was asked to provide Conflict Minerals data in the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Greater than 90% of these suppliers responded. Non-responsive suppliers and suppliers with inadequate responses were contacted multiple times. After this RCOI review, 329 smelters were identified as Conflict Minerals smelters consistent with the smelter definitions agreed upon by industry and the audit protocols published by the RMI. After performing a risk assessment on each of the 329 smelters regarding their responses, 41 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the suppliers as well as other public information available at the time. In accordance with the Rule, Lumentum is required to exercise due diligence on the Conflict Minerals’ source and chain of custody and to follow a nationally or internationally recognized due diligence framework.
Conflict Minerals Policy
Lumentum’s Conflict Minerals Policy is publicly available on our website at: https://www.lumentum.com/en/company/sustainability/our-business.
Risk Assessment and Response
Lumentum’s risk assessment plan was designed to define, identify, mitigate, and manage risks. Risks that arise are reported to the designated member of senior management. As described above under Reasonable Country of Origin Inquiry, Lumentum identified the smelters in its supply chain and directly contacted all 199 suppliers who reported the 329 smelters and performed a risk assessment regarding responses. 41 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information obtained directly from the suppliers as well as other public information available at the time. Lumentum then compared the identified smelter list to the list provided by the RMI and for smelters that were not identified as RMAP conformant, Lumentum conducted risk mitigation. 240 of 329 identified smelters (greater than 70%) have undergone an RMAP audit and were deemed conformant. These smelters were also reviewed against publicly available information to determine if there was any reason to believe that they directly or indirectly finance or benefit armed groups in the Covered Countries.
Due Diligence Results and Ongoing Risk Mitigation Efforts
Smelters
Of the 41 smelters that either confirmed they source Conflict Minerals from the Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, all 41 smelters were found to be RMAP conformant at the end of 2024. However, Lumentum became aware that one (1) smelter (L’Orfebre S.A.) was no longer RMAP Conformant as of January 2025. Accordingly, Lumentum is continuing its risk mitigation efforts in accordance with the OECD Due Diligence Guidance, including with suppliers that have reported L’Orfebre S.A. in their supply chains, to determine whether this smelter is actually used in the manufacture of products procured by Lumentum. A complete list of the identified smelters likely used in our supply chain is listed on Annex A hereto. In late 2024, Lumentum was made aware of escalating armed activity taking place in Eastern DRC. We have engaged with the Responsible Minerals Initiative to understand how its due diligence audits of smelters are adapting to the ongoing situation. The RMI’s statement on the conflict situation is available at www.responsiblemineralsinitiative.org/news/rmi-statement-on-conflict-in-eastern-drc-feb-2025/.
Steps to be Taken to Mitigate Risk
Lumentum is committed to continuous improvement in our due diligence process to further mitigate the risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts require suppliers to provide information that will allow us to evaluate their Conflict Minerals status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from certified smelters when sourcing material from the Covered Countries.
Given that we are a downstream company, many steps removed from the mining or processing of 3TG, and that we do not purchase raw ore or refined 3TG, Lumentum relies on independent third-party audits of smelters and refiners. Lumentum supports such independent third-party audits, including those conducted by the RMAP, through our financial support for the RMI. Lumentum also actively supports the goal of increasing smelter and refiner participation in the RMAP through our participation in the RMI and direct outreach to those smelters and encourage them to participate in the RMAP.
Additional Risk Factors
The statements included in this Conflict Minerals Report are based on the RCOI process and due diligence performed in good faith by Lumentum. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect our determinations regarding the status of our supply chain with respect to Conflict Minerals. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules, (iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) many suppliers and smelters are unfamiliar with the diligence process and information required to be provided due to this new regulation, which could lead to inaccurate responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in smelter audits, (xi) materials sourced from the Covered Countries could inaccurately be declared secondary materials, (xii) illegally tagged Conflict Minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult. This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lumentum’s actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to Conflict Minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and the Lumentum assumes no obligation to update such statements.
Annex A
Smelters and Refineries
Below is a list of the smelters reported to Lumentum as likely in Lumentum’s supply chain as of December 31, 2024.
| | | | | |
| Metal | Smelter Name |
| Gold | 8853 S.p.A. |
| Gold | ABC Refinery Pty Ltd. |
| Gold | Abington Reldan Metals, LLC |
| Gold | Advanced Chemical Company |
| Gold | Agosi AG |
| Gold | Aida Chemical Industries Co., Ltd. |
| Gold | Albino Mountinho Lda. |
| Gold | Alexy Metals |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao |
| Gold | Argor-Heraeus S.A. |
| Gold | ASAHI METALFINE, Inc. |
| Gold | Asahi Refining Canada Ltd. |
| Gold | Asahi Refining USA Inc. |
| Gold | Asaka Riken Co., Ltd. |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold | Attero Recycling Pvt Ltd |
| Gold | AU Traders and Refiners |
| Gold | Aurubis AG |
| Gold | Bangalore Refinery |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden Ronnskar |
| Gold | C. Hafner GmbH + Co. KG |
| Gold | Caridad |
| Gold | CCR Refinery - Glencore Canada Corporation |
| Gold | Cendres + Metaux S.A. |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | Coimpa Industrial LTDA |
| Gold | Daye Non-Ferrous Metals Mining Ltd. |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Dongwu Gold Group |
| Gold | Dowa |
| Gold | DSC (Do Sung Corporation) |
| Gold | Eco-System Recycling Co., Ltd. East Plant |
| Gold | Eco-System Recycling Co., Ltd. North Plant |
| Gold | Eco-System Recycling Co., Ltd. West Plant |
| Gold | Elite Industech Co., Ltd. |
| Gold | Emerald Jewel Industry India Limited (Unit 1) |
| Gold | Emerald Jewel Industry India Limited (Unit 2) |
| Gold | Emerald Jewel Industry India Limited (Unit 3) |
| Gold | Emerald Jewel Industry India Limited (Unit 4) |
| Gold | GG Refinery Ltd. |
| | | | | |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. |
| Gold | Gold by Gold Colombia |
| Gold | Gold Coast Refinery |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold | Guangdong Jinding Gold Limited |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Germany GmbH Co. KG |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ CO., LTD. |
| Gold | Impala Platinum - Base Metal Refinery (BMR) |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) |
| Gold | Impala Platinum - Rustenburg Smelter |
| Gold | Inca One (Chala One Plant) |
| Gold | Inca One (Koricancha Plant) |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Italpreziosi |
| Gold | JALAN & Company |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | JX Advanced Metals Corporation |
| Gold | K.A. Rasmussen |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kazzinc |
| Gold | Kennecott Utah Copper LLC |
| Gold | KGHM Polska Miedz Spolka Akcyjna |
| Gold | Kojima Chemicals Co., Ltd. |
| Gold | Korea Zinc Co., Ltd. |
| Gold | Kundan Care Products Ltd. |
| Gold | Kyrgyzaltyn JSC |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. |
| Gold | L'Orfebre S.A. |
| Gold | LS MnM Inc. |
| Gold | LT Metal Ltd. |
| Gold | Marsam Metals |
| Gold | Materion |
| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | MD Overseas |
| Gold | Metal Concentrators SA (Pty) Ltd. |
| Gold | Metallix Refining Inc. |
| Gold | Metalor Technologies (Hong Kong) Ltd. |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. |
| Gold | Metalor Technologies (Suzhou) Ltd. |
| Gold | Metalor Technologies S.A. |
| Gold | Metalor USA Refining Corporation |
| | | | | |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. |
| Gold | Minera Titan del Peru SRL (MTP) - Belen Plant |
| Gold | Mitsubishi Materials Corporation |
| Gold | Mitsui Mining and Smelting Co., Ltd. |
| Gold | MKS PAMP SA |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| Gold | Modeltech Sdn Bhd |
| Gold | Morris and Watson |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. |
| Gold | Navoi Mining and Metallurgical Combinat |
| Gold | NH Recytech Company |
| Gold | Nihon Material Co., Ltd. |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | Pease & Curren |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Precinox S.A. |
| Gold | QG Refining, LLC |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | Refinery of Seemine Gold Co., Ltd. |
| Gold | REMONDIS PMR B.V. |
| Gold | Royal Canadian Mint |
| Gold | SAAMP |
| Gold | Sabin Metal Corp. |
| Gold | Safimet S.p.A |
| Gold | SAFINA A.S. |
| Gold | Sai Refinery |
| Gold | Samduck Precious Metals |
| Gold | Samwon Metals Corp. |
| Gold | SEMPSA Joyeria Plateria S.A. |
| Gold | Shandong Gold Smelting Co., Ltd. |
| Gold | Shandong Humon Smelting Co., Ltd. |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Shenzhen CuiLu Gold Co., Ltd. |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sovereign Metals |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | Super Dragon Technology Co., Ltd. |
| Gold | T.C.A S.p.A |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | TITAN COMPANY LIMITED, JEWELLERY DIVISION |
| | | | | |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Torecom |
| Gold | Umicore Precious Metals Thailand |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| Gold | WEEEREFINING |
| Gold | Western Australian Mint (T/a The Perth Mint) |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Yunnan Copper Industry Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Gold | Zijin Mining Group Gold Smelting Co. Ltd. |
| | |
| Tantalum | AMG Brasil |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum | D Block Metals, LLC |
| Tantalum | F&X Electro-Materials Ltd. |
| Tantalum | FIR Metals & Resource Ltd. |
| Tantalum | Global Advanced Metals Aizu |
| Tantalum | Global Advanced Metals Boyertown |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum | Jiangxi Tuohong New Raw Material |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum | Jiujiang Tanbre Co., Ltd. |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum | KEMET de Mexico |
| Tantalum | Materion Newton Inc. |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
| Tantalum | Mineracao Taboca S.A. |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | NPM Silmet AS |
| Tantalum | PowerX Ltd. |
| Tantalum | QSIL Metals Hermsdorf GmbH |
| Tantalum | QuantumClean |
| Tantalum | Resind Industria e Comercio Ltda. |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. |
| Tantalum | Taki Chemical Co., Ltd. |
| Tantalum | TANIOBIS Co., Ltd. |
| Tantalum | TANIOBIS GmbH |
| Tantalum | TANIOBIS Japan Co., Ltd. |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| | | | | |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| | |
| Tin | Alpha Assembly Solutions Inc |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Aurubis Beerse |
| Tin | Aurubis Berango |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
| Tin | China Tin Group Co., Ltd. |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
| Tin | CRM Synergies |
| Tin | CV Ayi Jaya |
| Tin | CV Venus Inti Perkasa |
| Tin | Dongguan Best Alloys Co., Ltd. |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Dowa |
| Tin | DS Myanmar |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | EM Vinto |
| Tin | Estanho de Rondonia S.A. |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. |
| Tin | Feinhutte Halsbrucke GmbH |
| Tin | Fenix Metals |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd |
| Tin | Luna Smelter, Ltd. |
| Tin | Ma'anshan Weitai Tin Co., Ltd. |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
| Tin | Malaysia Smelting Corporation (MSC) |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) |
| Tin | Melt Metais e Ligas S.A. |
| Tin | Metallic Resources, Inc. |
| Tin | Mineracao Taboca S.A. |
| Tin | Mining Minerals Resources SARL |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | Modeltech Sdn Bhd |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | O.M. Manufacturing Philippines, Inc. |
| | | | | |
| Tin | Operaciones Metalurgicas S.A. |
| Tin | Pongpipat Company Limited |
| Tin | Precious Minerals and Smelting Limited |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Arsed Indonesia |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | PT Babel Inti Perkasa |
| Tin | PT Babel Surya Alam Lestari |
| Tin | PT Bangka Prima Tin |
| Tin | PT Bangka Serumpun |
| Tin | PT Bangka Tin Industry |
| Tin | PT Belitung Industri Sejahtera |
| Tin | PT Bukit Timah |
| Tin | PT Cipta Persada Mulia |
| Tin | PT Menara Cipta Mulia |
| Tin | PT Mitra Stania Prima |
| Tin | PT Mitra Sukses Globalindo |
| Tin | PT Premium Tin Indonesia |
| Tin | PT Prima Timah Utama |
| Tin | PT Putera Sarana Shakti (PT PSS) |
| Tin | PT Rajawali Rimba Perkasa |
| Tin | PT Rajehan Ariq |
| Tin | PT Refined Bangka Tin |
| Tin | PT Sariwiguna Binasentosa |
| Tin | PT Stanindo Inti Perkasa |
| Tin | PT Sukses Inti Makmur (SIM) |
| Tin | PT Timah Nusantara |
| Tin | PT Timah Tbk Kundur |
| Tin | PT Timah Tbk Mentok |
| Tin | PT Tinindo Inter Nusa |
| Tin | PT Tommy Utama |
| Tin | Resind Industria e Comercio Ltda. |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED |
| Tin | Rui Da Hung |
| Tin | Soft Metais Ltda. |
| Tin | Super Ligas |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. |
| Tin | Thaisarco |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. |
| Tin | Tin Technology & Refining |
| Tin | TRATHO Metal Quimica |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin | VQB Mineral and Trading Group JSC |
| Tin | White Solder Metalurgia e Mineracao Ltda. |
| Tin | Woodcross Smelting Company Limited |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
| | |
| Tungsten | A.L.M.T. Corp. |
| | | | | |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | China Molybdenum Tungsten Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | Cronimet Brasil Ltda |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | Global Tungsten & Powders LLC |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | Hubei Green Tungsten Co., Ltd. |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
| Tungsten | Japan New Metals Co., Ltd. |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten | KENEE MINING VIETNAM COMPANY LIMITED |
| Tungsten | Kennametal Fallon |
| Tungsten | Kennametal Huntsville |
| Tungsten | LAOS SOUTHERN MINING SMELTING SOLE CO.,LTD |
| Tungsten | Lianyou Metals Co., Ltd. |
| Tungsten | Lianyou Resources Co., Ltd. |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Masan High-Tech Materials |
| Tungsten | Niagara Refining LLC |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation |
| Tungsten | Philippine Carreytech Metal Corp. |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. |
| Tungsten | S.P.T. spol.s r.o. |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG |
| Tungsten | Tungsten Vietnam Joint Stock Company |
| Tungsten | Wolfram Bergbau und Hutten AG |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Xiamen Tungsten Co., Ltd. |
One of the smelters above declared to be sourcing, or there was reason to believe they may be sourcing, from the Covered Countries. This smelter was RMAP Conformant until January of 2025. Under the Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries and there is no requirement to identify the specific Covered Country by the smelter. Given the limitation on the specificity of the smelters’ disclosures, the identified Covered Country is the DRC.