Washington, D.C. 20549
Specialized Disclosure Report
(Exact name of registrant as specified in its charter)
(State or other jurisdiction
of incorporation or organization)
(Commission File Number)(I.R.S. Employer
Identification Number)
53 South Avenue
Burlington, Massachusetts 01803
(781) 418-7000
(Address of registrant’s principal executive office) (Zip Code)

James L. Baldwin, Jr.
Chief Legal Officer and General Counsel
53 South Avenue
Burlington, Massachusetts 01803
(781) 418-7000
(Name and telephone number, including area code, of person to contact in connection with this report)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this applies:
xRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2019

Section 1 - Conflict Minerals Disclosure

Items 1.01 and 1.02 Conflict Minerals Disclosure and Report, Exhibit

Conflict Minerals Disclosure

A copy of Keurig Dr Pepper Inc.’s ("KDP's") Conflict Minerals Report for the reporting period January 1, 2019 to December 31, 2019 is provided as Exhibit 1.01 hereto and is publicly available at https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance and http://investors.keurigdrpepper.com/sec-filings.*

Section 2 - Exhibits

Item 2.01 Exhibits

The following exhibit is filed as part of this report.
Exhibit No.Description
Conflict Minerals Report for the reporting period January 1, 2019 to December 31, 2019.


* The reference to KDP’s website is provided for convenience only, and its contents are not incorporated by reference into this Form SD nor the Conflicts Minerals Report nor deemed filed with the U.S. Securities and Exchange Commission.


Pursuant to the requirements of the Securities Exchange Act of 1934, the Registrant has duly caused this report to be signed on its behalf by the duly authorized undersigned.

By:/s/ James L. BaldwinMay 26, 2020
James L. Baldwin(Date)
Chief Legal Officer, Corporate General Counsel and Secretary

Exhibit 1.01
Keurig Dr Pepper Inc.
Conflict Minerals Report
For the reporting period from January 1, 2019 to December 31, 2019


Keurig Dr Pepper, Inc. (the “Company,” “KDP,” “we,” “us” or “our”) is committed to sourcing products, components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. To that end, we are committed to the ethical sourcing of minerals including tin, tantalum, tungsten and gold. There is concern that these “Conflict Minerals” could originate from certain mines in the Democratic Republic of the Congo (“DRC”) which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict in the region.

KDP has prepared this Conflict Minerals Report (this “Report”) pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2019 to December 31, 2019 (the “Reporting Period”).

This Report describes KDP’s due diligence process and compliance with the Rule’s requirements. The Rule requires disclosure of certain information when a reporting company manufactures, or contracts to manufacture, products which contain the minerals specified in the Rule, if those minerals are necessary to the functionality or production of such products. The specified minerals, which the Company collectively refers to in this Report as “3TG,” are gold, columbite-tantalite (coltan), cassiterite and wolframite and their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.

Reporting Scope

As described in this Report, certain 3TG are necessary to the functionality or production of products that the Company contracted to manufacture, or manufactured, during the Reporting Period. These products are the Company’s Keurig brewers and milk frother products, as well as coffee brewer products manufactured and sold by Keurig Canada Inc., an indirect wholly-owned subsidiary of KDP (such in-scope products, collectively, the “Covered Products”). There are no additional products that KDP contracted to manufacture, or manufactured, during the Reporting Period which are considered in-scope products according to the Rule.

Our Approach

KDP uses components and materials containing 3TG in its Covered Products but does not purchase 3TG directly from mines, smelters, or refiners. Therefore, we must collaborate with suppliers, industry peers, and other stakeholders as described in this Report to conduct appropriate due diligence on our upstream supply chains.

KDP is a member of the Responsible Minerals Initiative (“RMI”), a multi-industry initiative addressing Conflict Minerals issues in the supply chain (unique member code KEUR). The RMI’s Conflict Minerals Reporting Template (“CMRT”) is a widely-used standard form to collect information from the supply chain, including the names of 3TG smelters or refiners (“SORs”). RMI also manages the Responsible Minerals Assurance Process (“RMAP”), which uses independent third-party audits to assess whether 3TG SORs have systems in place to source 3TG in conformance with 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 (“OECD Guidance”)1. We use the CMRT to survey our suppliers and identify SORs in our supply chain, and the RMAP to determine the country of origin and conformance status of minerals.

In accordance with the Rule, KDP has in good faith conducted a reasonable country of origin inquiry (“RCOI”) regarding 3TG. This country of origin inquiry was designed to determine whether any of the 3TG used in the Covered Products originated in the Covered Countries and whether any of such 3TG may be from recycled or scrap sources. The Company also performed due diligence on the source and chain of custody of such 3TG based on the OECD Guidance and as described in more detail below.

Reasonable Country of Origin Inquiry

In 2019, KDP identified its direct suppliers believed or known to have provided materials, components or products which may contain Conflict Minerals, as well as one indirect component supplier with whom KDP engages directly (such direct suppliers and indirect supplier, collectively, the “Suppliers”). KDP requested that each Supplier submit information to KDP using the CMRT.

The information submitted by KDP’s Suppliers in their CMRTs included information gathered by those Suppliers about the smelters and refiners identified in their own supply chains which KDP utilized to conduct further due diligence. As described in more detail below, KDP’s Responsible Sourcing team reviewed and analyzed each CMRT received.

KDP compared the list of SORs reported by Suppliers against the RMI’s Smelter Database2 to first determine which of the reported entities are known to be true SORs of 3TG (“Eligible SORs”). The list of Eligible SORs that our Suppliers reported as being in their supply chains is set forth in Annex I. The list of countries from which KDP believes the 3TG in its Covered Products may have originated is set forth in Annex II. This information was obtained through KDP’s membership in the RMI, using the RCOI report dated March 27, 2020. Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP. Through our RCOI, we found that:

Some 3TG is sourced through SORs that are not yet RMAP-Conformant and therefore we have not yet determined the country of origin of those minerals;
Some 3TG is sourced from RMAP-Conformant SORs, including SORs that source responsibly from the Covered Countries; and
Some 3TG also may have originated from recycled or scrap sources.

1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition, 2016; https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
2 The RMI Smelter Database was exported and referenced as of our cutoff date of April 29, 2020:


In addition to the RMI RCOI data available to KDP, select Suppliers reported to KDP that they source from the Covered Countries in their CMRTs:
Several Suppliers reported that they source from the Covered Countries and reported to KDP the names of the SORs found to source from the Covered Counties. KDP referenced the RMI Smelter Database and confirmed that the SOR names provided are RMAP Conformant.
Two Suppliers provided SOR names that we confirmed have ceased operations or have been re-classified as non-smelters by the RMI.
Five Suppliers reported that they source from the Covered Countries but did not provide the corresponding SOR names. In this case, KDP could not cross reference Smelter Database for SOR Conformance status.

Ultimately, KDP relies on the RMI RCOI data as the most accurate information for our RCOI.

The information obtained from our Suppliers indicated that there was reason to believe that a portion of 3TG used in the Covered Products may have originated in the Covered Countries and were not exclusively from recycled or scrap sources, triggering the due diligence steps described in the following sections.

Due Diligence

Design of Due Diligence

KDP designed its due diligence measures in accordance with the OECD Guidance.

The OECD Guidance utilizes a five-step process for due diligence:

Step 1: Establish Strong Company Management Systems
Step 2: Identify and Assess Risks in the Supply Chain
Step 3: Design and Implement a Strategy to Respond to Identified Risks
Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices
Step 5: Report Annually on Supply Chain Due Diligence

Below is a description of KDP’s due diligence measures performed for the Reporting Period.

Due Diligence Measures Performed

Step 1: Establish Strong Company Management Systems:

The Company has adopted a policy relating to 3TG incorporating the standards set forth in the OECD Guidance (the “Conflict Minerals Policy”). The Conflict Minerals Policy is available on KDP’s website at https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance.

KDP’s Conflict Minerals Policy states in part that KDP is committed to: (1) supporting the aims and objectives of the U.S. legislation on the disclosure of 3TG; (2) not knowingly procuring 3TG that originates from facilities in the Covered Countries that are not considered conflict free; and (3) ensuring compliance with the KDP Conflict Minerals Policy.


Members from the Company’s Supply Chain, Legal, and Sustainability Teams were involved in the due diligence process, which was led by the Company’s Responsible Sourcing Team. Members of our Executive Leadership Team were briefed on the Company’s due diligence procedures and results, and reviewed and approved this Report.

Requirements related to Conflict Minerals and related due diligence activities are generally included in our most significant supplier contracts relating to Covered Products.

KDP has established a system of controls and transparency to determine the SORs in its 3TG supply chain by creating a process to engage Suppliers. KDP uses a third party software platform to collect, store, analyze and aggregate Supplier data for reporting purposes. It is also used to send automated reminders to Suppliers throughout the due diligence process.

KDP provided Suppliers with links to the RMI e-learning academy and other resources. Throughout the due diligence process, KDP also engaged in ongoing communication and provided support to its Suppliers to facilitate the completion of their CMRTs.

Suppliers and employees are encouraged to report any ethical concerns or violations by any KDP employee or agent acting on behalf of the supplier or KDP. Concerns or violations may be reported in the following ways:

Call: 800-349-4248 (U.S. & Canada) or 001-888-243-8076 (Mexico).
Mail: Attn: General Counsel | Keurig Dr Pepper | 5301 Legacy Drive | Plano, TX 75024.
Web: www.integrity-helpline.com/kdp.jsp

KDP retains Conflict Minerals documentation materials for five years after receipt.

Step 2: Identify and Assess Risks in the Supply Chain:

As described above, as part of its due diligence process KDP identified in scope Suppliers and requested that the Suppliers submit a completed CMRT.

Via our software platform, KDP then reviewed Suppliers’ completed CMRTs against a set of internally developed criteria for completeness and consistency. While 100% of Suppliers surveyed submitted a CMRT this year, there were several CMRTs that were incomplete or contained inconsistencies which we were unable to resolve with the supplier before our cutoff date of April 29, 2020 despite numerous follow up requests. We intend to work with these suppliers to improve their responses year over year.

For Suppliers that indicated in their responses that they or a supplier in their supply chain did use 3TG in their part(s) and/or product(s) during the Reporting Period and provided the applicable smelter or refiner information, the Company reconciled the reported SORs against the RMI Smelter Database, which contains RMAP SOR Conformance status. (Available to RMI members at http://www.responsiblemineralsinitiative.org/members/smelter-database/)

Step 3: Design and Implement a Strategy to Respond to Identified Risks:

Where SORs were reported that are not RMAP-Conformant or Active (engaged in the RMAP program but not yet audited), KDP sent a notice via the platform asking applicable Suppliers to either work with their supply-chain to request the smelter to participate in the RMAP audit program, and/or work to transition away from the smelter, depending on level of identified risk. There were also instances where inaccurate or outdated SOR information was reported to us, for example: smelters no longer in operation, or entities

that could not be identified as known SORs. In these cases, we sent a notification to Suppliers asking them to work with their supply chain to obtain accurate smelter information. Our smelter action requests specified that we expect to see continuous improvement year over year in the reported smelter information.

In addition to the above, we also review our Suppliers’ CMRTs for due diligence activities, such as whether they have their own Conflict Minerals Policy. See the Due Diligence Results section below where we report on the number of Suppliers who provided a policy that indicates a commitment to reasonably ensuring that only conflict-free materials and components are used in products/parts that are sold to KDP.

Further, several Suppliers indicated in their responses that they have not received complete information from their suppliers. When this happened, we requested that they work to improve their response rate.

Lastly, recognizing that the complexity of this issue requires a collaborative and cross-industry approach, we actively participate in the RMI’s China Smelter Engagement Team (the “China SET”). China SET’s purpose is to conduct coordinated outreach to SORs to encourage them to participate in RMAP or other equivalent third-party validation schemes. As a member of China SET, we work as the Single Point of Contact for three smelters to facilitate their engagement with RMI, including to communicate RMAP requirements to them, and to encourage them to maintain their status on the Conformant Smelter List.

Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices

As a member of the RMI, KDP leverages information from the independent third party audits of the SORs facilitated by initiatives such as the RMI’s RMAP and the London Bullion Market Association (LBMA), or Responsible Jewelry Council (RJC).

Step 5: Report Annually on Supply Chain Due Diligence:

As discussed above, KDP is reporting on supply chain due diligence by publishing a Conflict Minerals Report for the Reporting Period on KDP’s corporate website (https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance).

Due Diligence Results

Many of our Supplier responses represented their supply chain at a company level rather than being product specific. Therefore, the list of SORs contained in this Report may contain more SORs than those that actually process the conflict minerals contained in our products.


The total number of unique entities reported as SORs by the KDP supply base as a result of the 2019 survey was 361. Of these:
296 have been confirmed as being Eligible SORs by the RMI
61 were known to not be Eligible SORs, and
4 reported entities’ status could not be confirmed as of our cutoff date of April 29, 2020. This is compared to 6 entities in the prior year.

Of the 296 Eligible SORs reported by KDP Suppliers (for detail by mineral, please refer to Figure 1, below):
234, or 79% had been validated by the RMI RMAP program as Conformant to an RMI recognized audit protocol (RMAP, LBMA, or RJC), a 2% decrease from the prior year. This change is mainly attributed to a large number of previously operating Conformant Tin smelters which temporarily or permanently ceased operations during 2019 due to regulatory changes in Indonesia.
9 were in process or communication with RMAP, but had not achieved Conformant status as of April 26, 2020.
The remaining 53 have not been validated by the RMAP program as Conformant.

A list of all 296 of the Eligible SORs identified during the due diligence process is included in Annex I to this Report.

Figure 1: Conformance Status of Eligible SORs Reported by KDP Suppliers:


The 61 entities reported by our Suppliers that are not currently considered Eligible SORs fell into two categories:
6 companies that had been reclassified by RMI due to better understanding of their business (group company or did not meet the definition of a smelter), and
55 Eligible SORs that had either temporarily or permanently suspended operations.

As described above, we also requested Suppliers provide a policy that indicates a commitment to reasonably ensuring that only conflict free materials and components are used in products/parts sold to KDP. 58% of Suppliers provided a policy that meets this criterion, up from 40% in the prior year.


Future Due Diligence Improvements

KDP plans to continue to improve its due diligence measures by taking the following steps, among others:
Continuing to engage with Suppliers to obtain current, accurate and complete information about our supply chain;
Continuing to encourage Suppliers to improve their own due diligence processes including their own conflict minerals policy; and
Continuing to encourage Suppliers to request non-Conformant smelters to participate in the RMAP audit program, and/or work to transition away from such SORs.


Based on the information obtained pursuant to the due diligence process described above, KDP believes that the SORs that may have been used to process the 3TG in KDP products include the SORs listed in Annex I below. The list of countries from which KDP believes the 3TG in their products may have originated, as well as any materials from recycled and scrap sources, is set forth in Annex II. The SOR information collected from our Suppliers continued to include a number of SORs that had not been audited and determined to be RMAP Conformant by the RMI, or any other recognized organization.
KDP has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with KDP’s Conflict Minerals Policy, may affect KDP’s future determinations.

Annex I
List of Smelters and Refiners

The table below represents a consolidated list of SORs (296 in total) identified by KDP’s Suppliers. The results are based on:

Information provided by KDP’s Suppliers in their CMRTs; and
The Conformance status indicated in the RMI Smelter Database as of April 29, 2020

“SOR Country” refers to the location of the SOR, not the source of minerals. Refer to Annex II for the list of countries from which 3TG may have originated.

SORs that have been validated by the RMAP program as Conformant:
MetalSOR NameSOR CountrySOR ID
Gold8853 S.p.A.ITALYCID002763
GoldAdvanced Chemical CompanyUNITED STATES OF AMERICACID000015
GoldAida Chemical Industries Co., Ltd.JAPANCID000019
GoldAl Etihad Gold Refinery DMCCUNITED ARAB EMIRATESCID002560
GoldAllgemeine Gold-und Silberscheideanstalt A.G.GERMANYCID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)UZBEKISTANCID000041
GoldAngloGold Ashanti Corrego do Sitio MineracaoBRAZILCID000058
GoldArgor-Heraeus S.A.SWITZERLANDCID000077
GoldAsahi Pretec Corp.JAPANCID000082
GoldAsahi Refining Canada Ltd.CANADACID000924
GoldAsaka Riken Co., Ltd.JAPANCID000090
GoldAU Traders and RefinersSOUTH AFRICACID002850
GoldAurubis AGGERMANYCID000113
GoldBangalore RefineryINDIACID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)PHILIPPINESCID000128
GoldBoliden ABSWEDENCID000157
GoldC. Hafner GmbH + Co. KGGERMANYCID000176
GoldCCR Refinery - Glencore Canada CorporationCANADACID000185
GoldCendres + Metaux S.A.SWITZERLANDCID000189
GoldChimet S.p.A.ITALYCID000233
GoldChugai MiningJAPANCID000264
GoldDODUCO Contacts and Refining GmbHGERMANYCID000362
GoldDSC (Do Sung Corporation)KOREA, REPUBLIC OFCID000359
GoldEco-System Recycling Co., Ltd. East PlantJAPANCID000425
GoldEco-System Recycling Co., Ltd. North PlantJAPANCID003424

GoldEco-System Recycling Co., Ltd. West PlantJAPANCID003425
GoldGeib Refining CorporationUNITED STATES OF AMERICACID002459
GoldGold Refinery of Zijin Mining Group Co., Ltd.CHINACID002243
GoldHeimerle + Meule GmbHGERMANYCID000694
GoldHeraeus Metals Hong Kong Ltd.CHINACID000707
GoldHeraeus Precious Metals GmbH & Co. KGGERMANYCID000711
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CHINACID000801
GoldIshifuku Metal Industry Co., Ltd.JAPANCID000807
GoldIstanbul Gold RefineryTURKEYCID000814
GoldJapan MintJAPANCID000823
GoldJiangxi Copper Co., Ltd.CHINACID000855
GoldJX Nippon Mining & Metals Co., Ltd.JAPANCID000937
GoldKennecott Utah Copper LLCUNITED STATES OF AMERICACID000969
KGHM Polska Miedz Spolka Akcyjna
GoldKojima Chemicals Co., Ltd.JAPANCID000981
GoldKorea Zinc Co., Ltd.KOREA, REPUBLIC OFCID002605
GoldKyrgyzaltyn JSCKYRGYZSTANCID001029
GoldL'Orfebre S.A.ANDORRACID002762
GoldMarsam MetalsBRAZILCID002606
GoldMatsuda Sangyo Co., Ltd.JAPANCID001119
GoldMetalor Technologies (Hong Kong) Ltd.CHINACID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.SINGAPORECID001152
GoldMetalor Technologies (Suzhou) Ltd.CHINACID001147
GoldMetalor Technologies S.A.SWITZERLANDCID001153
GoldMetalor USA Refining CorporationUNITED STATES OF AMERICACID001157
GoldMetalurgica Met-Mex Penoles S.A. De C.V.MEXICOCID001161
GoldMitsubishi Materials CorporationJAPANCID001188
GoldMitsui Mining and Smelting Co., Ltd.JAPANCID001193
GoldMMTC-PAMP India Pvt., Ltd.INDIACID002509
GoldMoscow Special Alloys Processing PlantRUSSIAN FEDERATIONCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.S.TURKEYCID001220
GoldNihon Material Co., Ltd.JAPANCID001259
GoldOgussa Osterreichische Gold- und Silber-Scheideanstalt GmbHAUSTRIACID002779
GoldOhura Precious Metal Industry Co., Ltd.JAPANCID001325
GoldOJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet)RUSSIAN FEDERATIONCID001326

GoldOJSC Novosibirsk RefineryRUSSIAN FEDERATIONCID000493
GoldPlanta Recuperadora de Metales SpACHILECID002919
GoldPrioksky Plant of Non-Ferrous MetalsRUSSIAN FEDERATIONCID001386
GoldPT Aneka Tambang (Persero) TbkINDONESIACID001397
GoldPX Precinox S.A.SWITZERLANDCID001498
GoldRand Refinery (Pty) Ltd.SOUTH AFRICACID001512
GoldRoyal Canadian MintCANADACID001534
GoldSafimet S.p.AITALYCID002973
GoldSamduck Precious MetalsKOREA, REPUBLIC OFCID001555
GoldSAXONIA Edelmetalle GmbHGERMANYCID002777
GoldSEMPSA Joyeria Plateria S.A.SPAINCID001585
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CHINACID001622
GoldSichuan Tianze Precious Metals Co., Ltd.CHINACID001736
GoldSingway Technology Co., Ltd.TAIWAN, PROVINCE OF CHINACID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsRUSSIAN FEDERATIONCID001756
GoldSolar Applied Materials Technology Corp.TAIWAN, PROVINCE OF CHINACID001761
GoldSumitomo Metal Mining Co., Ltd.JAPANCID001798
GoldSungEel HiMetal Co., Ltd.KOREA, REPUBLIC OFCID002918
GoldT.C.A S.p.AITALYCID002580
GoldTanaka Kikinzoku Kogyo K.K.JAPANCID001875
GoldThe Refinery of Shandong Gold Mining Co., Ltd.CHINACID001916
GoldTokuriki Honten Co., Ltd.JAPANCID001938
GoldTOO Tau-Ken-AltynKAZAKHSTANCID002615
GoldUmicore Brasil Ltda.BRAZILCID001977
GoldUmicore Precious Metals ThailandTHAILANDCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningBELGIUMCID001980
GoldUnited Precious Metal Refining, Inc.UNITED STATES OF AMERICACID001993
GoldValcambi S.A.SWITZERLANDCID002003
GoldWestern Australian Mint (T/a The Perth Mint)AUSTRALIACID002030
GoldWIELAND Edelmetalle GmbHGERMANYCID002778
GoldYamakin Co., Ltd.JAPANCID002100
GoldYokohama Metal Co., Ltd.JAPANCID002129
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCHINACID002224
TantalumAsaka Riken Co., Ltd.JAPANCID000092
TantalumChangsha South Tantalum Niobium Co., Ltd.CHINACID000211

TantalumF&X Electro-Materials Ltd.CHINACID000460
TantalumFIR Metals & Resource Ltd.CHINACID002505
TantalumGlobal Advanced Metals AizuJAPANCID002558
TantalumGlobal Advanced Metals BoyertownUNITED STATES OF AMERICACID002557
TantalumGuangdong Zhiyuan New Material Co., Ltd.CHINACID000616
TantalumH.C. Starck Co., Ltd.THAILANDCID002544
TantalumH.C. Starck Hermsdorf GmbHGERMANYCID002547
TantalumH.C. Starck Ltd.JAPANCID002549
TantalumH.C. Starck Smelting GmbH & Co. KGGERMANYCID002550
TantalumH.C. Starck Tantalum and Niobium GmbHGERMANYCID002545
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CHINACID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CHINACID002512
TantalumJiangxi Tuohong New Raw MaterialCHINACID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CHINACID000914
TantalumJiujiang Tanbre Co., Ltd.CHINACID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CHINACID002506
TantalumKEMET Blue MetalsMEXICOCID002539
TantalumLSM Brasil S.A.BRAZILCID001076
TantalumMetallurgical Products India Pvt., Ltd.INDIACID001163
TantalumMineracao Taboca S.A.BRAZILCID001175
TantalumMitsui Mining and Smelting Co., Ltd.JAPANCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CHINACID001277
TantalumNPM Silmet ASESTONIACID001200
TantalumResind Industria e Comercio Ltda.BRAZILCID002707
TantalumSolikamsk Magnesium Works OAORUSSIAN FEDERATIONCID001769
TantalumTaki Chemical Co., Ltd.JAPANCID001869
TantalumUlba Metallurgical Plant JSCKAZAKHSTANCID001969
TantalumXinXing HaoRong Electronic Material Co., Ltd.CHINACID002508
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.CHINACID001522
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CHINACID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CHINACID003190
TinChina Tin Group Co., Ltd.CHINACID001070

TinFenix MetalsPOLANDCID000468
TinGejiu Kai Meng Industry and Trade LLCCHINACID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CHINACID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CHINACID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CHINACID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CHINACID003116
TinGuanyang Guida Nonferrous Metal Smelting PlantCHINACID002849
TinHuiChang Hill Tin Industry Co., Ltd.CHINACID002844
TinHuichang Jinshunda Tin Co., Ltd.CHINACID000760
TinJiangxi New Nanshan Technology Ltd.CHINACID001231
TinMa'anshan Weitai Tin Co., Ltd.CHINACID003379
TinMagnu's Minerais Metais e Ligas Ltda.BRAZILCID002468
TinMalaysia Smelting Corporation (MSC)MALAYSIACID001105
TinMelt Metais e Ligas S.A.BRAZILCID002500
TinMetallic Resources, Inc.UNITED STATES OF AMERICACID001142
TinMetallo Belgium N.V.BELGIUMCID002773
TinMetallo Spain S.L.U.SPAINCID002774
TinMineracao Taboca S.A.BRAZILCID001173
TinMitsubishi Materials CorporationJAPANCID001191
TinO.M. Manufacturing (Thailand) Co., Ltd.THAILANDCID001314
TinO.M. Manufacturing Philippines, Inc.PHILIPPINESCID002517
TinOperaciones Metalurgicas S.A.BOLIVIA (PLURINATIONAL STATE OF)CID001337
TinPT Artha Cipta LanggengINDONESIACID001399
TinPT ATD Makmur Mandiri JayaINDONESIACID002503
TinPT Menara Cipta MuliaINDONESIACID002835
TinPT Mitra Stania PrimaINDONESIACID001453
TinPT Refined Bangka TinINDONESIACID001460
TinPT Timah Tbk KundurINDONESIACID001477
TinPT Timah Tbk MentokINDONESIACID001482
TinResind Industria e Comercio Ltda.BRAZILCID002706
TinSoft Metais Ltda.BRAZILCID001758
TinThai Nguyen Mining and Metallurgy Co., Ltd.VIETNAMCID002834
TinTin Technology & RefiningUNITED STATES OF AMERICACID003325
TinWhite Solder Metalurgia e Mineracao Ltda.BRAZILCID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CHINACID002158
TinYunnan Tin Company LimitedCHINACID002180

TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CHINACID003397
TungstenA.L.M.T. Corp.JAPANCID000004
TungstenACL Metais EireliBRAZILCID002833
TungstenAsia Tungsten Products Vietnam Ltd.VIETNAMCID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CHINACID002513
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CHINACID000258
TungstenFujian Ganmin RareMetal Co., Ltd.CHINACID003401
TungstenFujian Jinxin Tungsten Co., Ltd.CHINACID000499
TungstenGanzhou Haichuang Tungsten Co., Ltd.CHINACID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CHINACID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CHINACID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CHINACID002494
TungstenGlobal Tungsten & Powders Corp.UNITED STATES OF AMERICACID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CHINACID000218
TungstenH.C. Starck Smelting GmbH & Co. KGGERMANYCID002542
TungstenH.C. Starck Tungsten GmbHGERMANYCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CHINACID000766
TungstenHunan Chuangda Vanadium Tungsten Co., Ltd. WujiCHINACID002579
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CHINACID000769
TungstenHunan Litian Tungsten Industry Co., Ltd.CHINACID003182
TungstenHydrometallurg, JSCRUSSIAN FEDERATIONCID002649
TungstenJapan New Metals Co., Ltd.JAPANCID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CHINACID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CHINACID002321
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CHINACID002318
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CHINACID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CHINACID002316
TungstenKennametal FallonUNITED STATES OF AMERICACID000966
TungstenKennametal HuntsvilleUNITED STATES OF AMERICACID000105
TungstenLianyou Metals Co., Ltd.TAIWAN, PROVINCE OF CHINACID003407
TungstenMalipo Haiyu Tungsten Co., Ltd.CHINACID002319
TungstenMasan Tungsten Chemical LLC (MTC)VIETNAMCID002543
TungstenMoliren Ltd.RUSSIAN FEDERATIONCID002845
TungstenNiagara Refining LLCUNITED STATES OF AMERICACID002589
TungstenPhilippine Chuangxin Industrial Co., Inc.PHILIPPINESCID002827
TungstenTejing (Vietnam) Tungsten Co., Ltd.VIETNAMCID001889
TungstenUnecha Refractory metals plantRUSSIAN FEDERATIONCID002724
TungstenWolfram Bergbau und Hutten AGAUSTRIACID002044

TungstenWoltech Korea Co., Ltd.KOREA, REPUBLIC OFCID002843
TungstenXiamen Tungsten (H.C.) Co., Ltd.CHINACID002320
TungstenXiamen Tungsten Co., Ltd.CHINACID002082
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CHINACID002830
TungstenXinhai Rendan Shaoguan Tungsten Co., Ltd.CHINACID002095

SORs that have not been validated by the RMAP program as Conformant:
MetalSOR NameSOR CountrySOR ID
GoldAbington Reldan Metals, LLCUNITED STATES OF AMERICACID002708
GoldAfrican Gold RefineryUGANDACID003185
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.TURKEYCID000103
GoldCGR Metalloys Pvt Ltd.INDIACID003382
GoldDaye Non-Ferrous Metals Mining Ltd.CHINACID000343
GoldDegussa Sonne / Mond Goldhandel GmbHGERMANYCID002867
GoldDijllah Gold Refinery FZCUNITED ARAB EMIRATESCID003348
GoldFidelity Printers and Refiners Ltd.ZIMBABWECID002515
GoldGCC Gujrat Gold Centre Pvt. Ltd.INDIACID002852
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCHINACID001909
GoldGuangdong Jinding Gold LimitedCHINACID002312
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CHINACID000651
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CHINACID000671
GoldHunan Chenzhou Mining Co., Ltd.CHINACID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CHINACID000773
GoldInternational Precious Metal RefinersUNITED ARAB EMIRATESCID002562
GoldJSC Ekaterinburg Non-Ferrous Metal Processing PlantRUSSIAN FEDERATIONCID000927
GoldKaloti Precious MetalsUNITED ARAB EMIRATESCID002563
GoldKazakhmys Smelting LLCKAZAKHSTANCID000956
GoldKyshtym Copper-Electrolytic Plant ZAORUSSIAN FEDERATIONCID002865
GoldL'azurde Company For JewelrySAUDI ARABIACID001032
GoldLingbao Gold Co., Ltd.CHINACID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CHINACID001058
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CHINACID001093
GoldModeltech Sdn BhdMALAYSIACID002857
GoldMorris and WatsonNEW ZEALANDCID002282
GoldNavoi Mining and Metallurgical CombinatUZBEKISTANCID001236

GoldNH Recytech CompanyKOREA, REPUBLIC OFCID003189
GoldPenglai Penggang Gold Industry Co., Ltd.CHINACID001362
GoldRefinery of Seemine Gold Co., Ltd.CHINACID000522
GoldSai RefineryINDIACID002853
GoldSamwon Metals Corp.KOREA, REPUBLIC OFCID001562
GoldShandong Humon Smelting Co., Ltd.CHINACID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CHINACID001619
GoldSovereign MetalsINDIACID003383
GoldState Research Institute Center for Physical Sciences and TechnologyLITHUANIACID003153
GoldSudan Gold RefinerySUDANCID002567
GoldTongling Nonferrous Metals Group Co., Ltd.CHINACID001947
GoldTony Goetz NVBELGIUMCID002587
GoldYunnan Copper Industry Co., Ltd.CHINACID000197
TinAn Vinh Joint Stock Mineral Processing CompanyVIETNAMCID002703
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CHINACID003356
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSCVIETNAMCID002572
TinEstanho de Rondonia S.A.BRAZILCID000448
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CHINACID003410
TinModeltech Sdn BhdMALAYSIACID002858
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyVIETNAMCID002573
TinPongpipat Company LimitedMYANMARCID003208
TinPrecious Minerals and Smelting LimitedINDIACID003409
TinSuper LigasBRAZILCID002756
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyVIETNAMCID002574
TungstenCNMC (Guangxi) PGMA Co., Ltd.CHINACID000281
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CHINACID002313
TungstenJiangxi Xianglu Tungsten Co., Ltd.CHINACID002647
TungstenJSC "Kirovgrad Hard Alloys Plant"RUSSIAN FEDERATIONCID003408


Annex II
Countries from which the minerals in the Covered Products may have originated
Based on RMI’s Reasonable Country of Origin Inquiry report dated March 27, 2020, the countries of origin of the 3TG processed by SORs listed in ANNEX I are believed to include the countries identified below. Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP:

Bolivia (Plurinational-State of)LiberiaUganda
BrazilMalaysiaUnited Kingdom of Great Britain and Northern Ireland
Burkina FasoMaliUnited States of America
Congo, Democratic Republic of theNamibia
Dominican RepublicNew Zealand
EritreaPapua New Guinea
FinlandPuerto Rico
GeorgiaRussian Federation
GuatemalaSaudi Arabia
IndonesiaSolomon Islands
South Africa
Ivory CoastSpain
3 Minerals from this country were substantially transformed before being incorporated into finished products. Such a substantial transformation of the minerals happened outside of the United States in a third country by a person other than a United States person.

Bolivia (Plurinational-State of)GermanyRussian Federation
BurundiIndiaSierra Leone
Congo, Democratic-Republic of theMozambiqueThailand
AustraliaGuineaRussian Federation
Bolivia (Plurinational-State of)IndonesiaRwanda
Congo, Democratic-Republic of theMyanmarUnited Kingdom of Great-Britain and Northern Ireland
Bolivia (Plurinational-State of)Portugal
BrazilRussian Federation
Congo, Democratic-Republic of theTaiwan
LaosUnited Kingdom of Great-Britain and Northern Ireland
MalaysiaUnited States of America