UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549


FORM SD
Specialized Disclosure Report
________________________________________________________________________________________________________________________________
Aptiv PLC
(Exact name of registrant as specified in its charter)
________________________________________________________________________________________________________________________________
Jersey001-35346
(State or other jurisdiction of incorporation)(Commission file number)
5 Hanover Quay
Grand Canal Dock
Dublin, Ireland
D02 VY79
(Address of principal executive offices)(Zip code)
Katherine H. Ramundo
(248) 813-3005
(Name and telephone number, including area code, of the person to contact in connection with this report.)

Check the appropriate box to indicate the rule pursuant to which this form is being filed:
ýRule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2021.
Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____________________.




Section 1 – Conflict Minerals Disclosure
Item 1.01Conflict Minerals Disclosure and Report
Aptiv PLC (“Aptiv” or the “Company”), after performing the steps required by Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”), has concluded in good faith that during the year ended December 31, 2021, it manufactured products as to which Conflict Minerals (as defined in the Rule) were necessary to the functionality or production of such products.

Accordingly, Aptiv has filed this Specialized Disclosure Form (Form SD) and the attached Conflict Minerals Report. The Conflict Minerals Report and the Company’s Conflict Minerals policy are publicly available at aptiv.com. The information contained on Aptiv’s website is not a part of this Form SD and is not deemed incorporated by reference into this Form SD or any other public filing made with the Securities and Exchange Commission.

Item 1.02Exhibit

A copy of the Company's Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at aptiv.com.

Section 2 – Resource Extraction Issuer Disclosure
Item 2.01Resource Extraction Issuer Disclosure and Report
Not applicable.

Section 3 – Exhibits
Item 3.01Exhibits
Exhibit 1.01 - Conflict Minerals Report of Aptiv PLC for the period January 1 to December 31, 2021, as required by Items 1.01 and 1.02 of this Form.
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SIGNATURES
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.
Date:May 27, 2022 APTIV PLC
 
 By:/s/ Katherine H. Ramundo
Katherine H. Ramundo
Senior Vice President, Chief Legal Officer, Chief Compliance Officer and Secretary

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EXHIBIT INDEX
Exhibit
NumberDescription
1.01

4

Document
aptivimagea01a.jpg
Exhibit 1.01
Aptiv PLC
Conflict Minerals Report
For the Year Ended December 31, 2021

Introduction and Background

This Conflict Minerals Report (“CMR”) for the year ended December 31, 2021 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the “Rule”). The Rule imposes certain reporting obligations on U.S. Securities and Exchange Commission (“SEC”) registrants whose manufactured products contain certain minerals which are necessary to the functionality or production of their products. These minerals are cassiterite, columbite-tantalite (coltan), gold, wolframite and their derivatives, which are limited to tin, tantalum and tungsten (“3TG” or “Conflict Minerals”). The Rule focuses on 3TG emanating from the Democratic Republic of the Congo (“DRC”) region and nine adjoining countries (together, the “Covered Countries”). If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the registrant must exercise due diligence on the Conflict Minerals’ source and chain of custody and submit a CMR to the SEC that includes a description of those due diligence measures.

This CMR relates to the process undertaken for Aptiv products that were manufactured, or contracted to be manufactured, during calendar year 2021 and that contain Conflict Minerals. This CMR was not subjected to an independent private sector audit, as none was required pursuant to the guidance provided by the SEC in its “Statement on the Effect of the Recent Court of Appeals Decision on the Conflict Minerals Rule” dated April 29, 2014.

This report has been prepared by management of Aptiv PLC (herein referred to as “Aptiv,” the “Company,” “we,” “us” or “our”). The information includes the activities of all consolidated subsidiaries in which Aptiv holds a controlling financial or management interest and which meet the guidelines for inclusion based on the acquisition date. It does not include the activities of non-controlled affiliates that are not required to be consolidated.

Executive Summary of the 2021 Conflict Minerals Program

In order to determine the sources of 3TG in its supply chain, Aptiv performed a Reasonable Country of Origin Inquiry (“RCOI”) by surveying the relevant portion of our supply base for 3TG use. As a result of these survey procedures, 340 smelters and refineries (herein collectively referred to as “smelters”) were identified. Of these 340 smelters, 46 were identified as sourcing, or we had reason to believe may be sourcing, from the Covered Countries. We then exercised due diligence procedures over these 46 smelters, and as a result identified that 36 of these 46 smelters have been audited and are recognized as conformant with the Responsible Minerals Assurance Process (“RMAP”). The remaining 10 smelters were subject to Aptiv's risk mitigation process according to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chain of Minerals from Conflict-Affected and High-Risk Areas. As part of our due diligence procedures, we communicated concerns to the applicable suppliers in our supply chain that source from these smelters and encouraged our suppliers to take appropriate action to remove these smelters from their supply chain and to encourage the smelters to become RMAP Conformant.

I. Company Overview

Aptiv is a leading global technology and mobility architecture company primarily serving the automotive sector. We deliver end-to-end mobility solutions, enabling our customers’ transition to more electrified, software-defined vehicles. We design and manufacture vehicle components and provide electrical, electronic and active safety technology solutions to the global automotive and commercial vehicle markets. Aptiv is one of the largest vehicle technology suppliers, and its customers include the 25 largest automotive original equipment manufacturers in the world. As of December 31, 2021, we operated 127 major manufacturing facilities and 12 major technical centers, with a presence in 46 countries.

Products

As of December 31, 2021, we operated our core business along two operating segments, grouped on the basis of similar product, market and operating factors:

Signal and Power Solutions. This segment provides complete design, manufacture and assembly of the vehicle's electrical architecture, including engineered component products, connectors, wiring assemblies and harnesses, cable management, electrical centers and hybrid high voltage and safety distribution systems. Core product lines include:
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High quality connectors are engineered primarily for use in the automotive and related markets, but also have applications in the industrial, telematics, aerospace, defense and medical sectors.
Electrical centers provide centralized electrical power and signal distribution and all of the associated circuit protection and switching devices, thereby optimizing the overall vehicle electrical system.
Distribution systems, including hybrid high voltage systems, are integrated into one optimized vehicle electrical system that can utilize smaller cable and gauge sizes and ultra-thin wall insulation.

Advanced Safety and User Experience. This segment provides critical technologies, systems integration and advanced software development for vehicle safety, security, comfort and convenience, including sensing and perception systems, electronic control units, multi-domain controllers, vehicle connectivity systems, application software and autonomous driving technologies. Core product lines include:
Advanced safety primarily consists of solutions that enable active and passive safety features and vehicle automation, as well as vision, radar, LiDAR and other sensing technologies.
The user experience portfolio primarily enables in-cabin solutions around infotainment, driver interface and interior sensing solutions.
Connectivity and security products primarily consists of solutions that provide body control, security and unlock vehicle data.

Following completion of our due diligence measures, as described below, it was determined that, like many of our peers in the automotive industry, Aptiv’s products contain 3TG materials. Aptiv considers these 3TG materials necessary to the functionality or production of a significant portion of our manufactured products in both of our operating segments. Aptiv has designed and implemented a Conflict Minerals process, including performance of due diligence measures, to be consistent, in all material respects, with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on tantalum, tin, tungsten and gold (the “OECD Guidance”).

II. Reasonable Country of Origin Inquiry

We procure our raw materials and components from a variety of suppliers around the world. We rely on our direct suppliers to provide information on the source of the 3TG materials contained in components and materials supplied to us - including sources of 3TG that are supplied to them from upstream suppliers.

In order to understand the sources of 3TG in our supply chain, we performed an RCOI. Aptiv’s RCOI process involved two stages: Supplier RCOI, which was designed and performed in accordance with Step 2A of the OECD Guidance, and Smelter RCOI, which was designed and performed in accordance with Steps 2B, C and D of the OECD Guidance. While we utilize a third party provider to assist us in the survey process and to perform the smelter RCOI, we manage the overall process and engage with suppliers as part of the due diligence process, as further described below.

Supplier RCOI

Aptiv designed its Supplier RCOI process to identify, to the best of its efforts, the smelters of 3TG within Aptiv’s supply chain in accordance with Step 2A of the OECD Guidance. Aptiv conducted a good faith, risk-based applicability assessment of its supply base to identify those suppliers that were reasonably believed to supply products or components to us that may contain 3TG. Aptiv identified the suppliers based on information in its material data system, including the International Material Data System, assessments by Aptiv purchasing and materials personnel and prior year supplier Conflict Minerals Reporting Template (“CMRT”) submissions. Aptiv's supplier RCOI process included surveying the identified relevant suppliers (which represented approximately 725 suppliers and/or original manufacturers that supply parts and materials for products manufactured by Aptiv that we believe may contain 3TG). Aptiv’s 2021 RCOI process was designed to include substantially all of the parts and materials necessary to the functionality or production of products manufactured by Aptiv in 2021. Aptiv did not include suppliers of indirect material, such as packaging or office supplies, or providers of services, in its supplier survey.

These relevant suppliers and original manufacturers were contacted, provided with Aptiv’s Conflict Minerals Policy and requested to disclose to us the sources of 3TG materials used in the products sold to us, including smelter information, via the CMRT developed by the Responsible Minerals Initiative (“RMI”). At the same time, we defined and provided instructions regarding the expected due diligence of high risk smelters that may be reported. We reviewed all supplier responses for
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completeness and accuracy. For suppliers that did not provide adequate responses, where additional follow-up was needed based on the Company’s internal risk assessment methodology, or if responses were not provided in a timely manner, we actively solicited clarifications and responses.

Our 2021 RCOI and supplier response results represented approximately 95% of the Company’s total Annual Purchase Value (“APV”) from the relevant suppliers. After review of these responses, Aptiv consolidated the supplier responses into a single list of unique smelter names which met the definition of a smelter under one of three industry recognized audit protocols. We then reviewed this listing of smelters and compared it to the RMI list of known smelters in order to determine if we had identified reasonably all of the smelters in our supply chain. As a result of the supplier RCOI process, 340 smelters of 3TG were identified by our suppliers.

The large majority of the CMRT responses received from our suppliers provided data to us at a total company level, and our suppliers were unable to specify the smelters or refiners used for the specific components supplied to us during the reporting period. We are therefore unable to determine whether the 3TGs reported by our suppliers were contained in components or parts supplied to us during the reporting period. We are also unable to verify that all of the 3TG smelters that our suppliers identified were part of our supply chain. Based on the information provided by our suppliers, we made a reasonable good faith effort to collect and evaluate the information concerning 3TG smelters in our supply chain.

Smelter RCOI

Aptiv assessed the country of origin information for the 340 smelters identified by our suppliers, and determined that 46 of these smelters either source, or Aptiv had reason to believe they may source, 3TG from the Covered Countries. Due to the overlap between smelter RCOI and smelter due diligence, our smelter RCOI process is summarized below in the Due Diligence section of this report.

III. Due Diligence Process

Establishment of Strong Company Management Systems (OECD Step 1)

In accordance with Step 1 of the OECD Guidance, Aptiv has established a management system for Conflict Minerals, which includes:

Company Policies (1A) - Aptiv has adopted a Conflict Minerals Policy which is publicly available at aptiv.com/legal-compliance/policies. Aptiv communicated its policy directly to its suppliers as part of the RCOI process, as further described below.
Internal Management Team (1B) - We maintain a cross-functional Conflict Minerals Team to support Aptiv's supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program, including compliance activities associated with the Rule. The Conflict Minerals Team periodically reports the status of Aptiv's Conflict Minerals program to a Conflict Minerals Steering Committee comprised of designated senior management members, including the Senior Vice President, Chief Legal Officer, Chief Compliance Officer and Secretary, the Senior Vice President of Supply Chain Management and the Vice President of Operations.
System of Supply Chain Controls and Transparency (1C) - We established a system of controls over the Company's mineral supply chain, including the implementation of a process to collect information to perform the RCOI and due diligence procedures described below, as well as a risk assessment methodology designed to define, identify, mitigate and manage risks. Should a risk arise, it would be reported to the Conflict Minerals Steering Committee.
Aptiv supports an industry-wide approach to addressing social responsibility matters regarding Conflict Minerals. During the 2021 reporting period, Aptiv was an active member in the Responsible Minerals Working Group of the Automotive Industry Action Group (“AIAG”) as well as the Smelter Engagement Team, which regularly contacts non-conformant smelters to encourage participation in the RMAP. We also participate in several subcommittees as an active member of the RMI, which is an initiative of the Responsible Business Alliance. The RMI designed and manages the RMAP to identify the smelters that process 3TG and independently audit those smelters to validate company level management processes for responsible mineral procurement. The data on which we relied for certain statements in this report was obtained through our membership in the RMI, using the RCOI report for members. In addition, we participate in several RMI subgroups to support industry initiatives and keep informed of current and developing issues.
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Supplier Engagement (1D) - Due to our size and the nature of our products, and the corresponding size and depth of our supply chain, it is difficult to identify actors upstream from our direct suppliers. We rely on our suppliers to provide us with information concerning the source and chain of custody of 3TG contained in the products and components they supply. Many of our suppliers are also subject to the Rule, and they rely on information provided by their upstream suppliers. Our standard global contract terms and conditions require suppliers to provide information with respect to the origin of their products supplied to Aptiv. We also communicated with suppliers regarding our Conflict Minerals program, as detailed in this Conflict Minerals Report, which included direct engagement with our suppliers to collect required supplier and smelter RCOI and due diligence data, as further described below. This engagement included providing training to our suppliers on our Conflict Minerals program, if such assistance was requested by a supplier. We continue to maintain and communicate to our suppliers a dedicated email address (conflict.minerals@aptiv.com) to facilitate supplier communication with us regarding Conflict Minerals.
As a downstream entity, we drive responsible sourcing through our supply chain by exercising due diligence over our suppliers’ sourcing of raw materials in their upstream supply chains. We mitigate risks associated with the sourcing of 3TGs by working with our suppliers to identify 3TG smelters and refiners and encouraging those facilities to become RMAP Conformant. We also support broader industry efforts to promote responsible mining and sourcing, as further described above.
Grievance Mechanism (1E) - We have grievance mechanisms through which our employees and suppliers can report suspected or potential violations of our policies, laws or general ethics or compliance concerns. We maintain an email address (conflict.minerals@aptiv.com) for suppliers to ask questions, voice concerns and report violations with respect to our Conflict Minerals program. Aptiv also maintains a reporting system that allows employees and others to ask questions, voice concerns and report violations with respect to Aptiv policies confidentially and anonymously.

Identification and Assessment of Risks in the Supply Chain (OECD Step 2)

As described in the Reasonable Country of Origin section above, we surveyed our supply base to identify the smelters in their supply chain, as well as the country of origin, source and chain of custody of 3TGs in order to identify each of the smelters that placed Conflict Minerals into our supply chain, which we believed would facilitate our ability to identify the source and chain of custody of the Conflict Minerals contained in our products. Through our membership in the RMI, we reviewed RMAP information to assist us in determining whether a smelter was sourcing Conflict Minerals in a socially responsible manner, as further described below.

Design and Implement a Strategy to Respond to Risks (OECD Step 3)

In response to the risk assessment described in the foregoing section, Aptiv has an approved risk management process through which the Conflict Minerals program is implemented, managed and monitored. Aptiv performs risk mitigation on any high risk smelter (smelters that are identified as sourcing, or believed to be sourcing, from the Covered Countries) that is not recognized as RMAP Conformant. Aptiv’s risk mitigation process was designed in accordance with Step 3B of the OECD Guidance and is reported to the designated members of senior management that comprise the Conflict Minerals Steering Committee in accordance with Step 3A of the OECD Guidance. If there is reason to believe the smelters subject to Aptiv’s risk mitigation process were directly or indirectly financing or benefiting armed groups in the Covered Countries, Aptiv would initiate action with our suppliers for the removal of this smelter from our supply base, which is consistent with Step 3B of the OECD Guidance and helps prevent unnecessary boycotts of the Covered Countries.

Third Party Audit of Supply Chain Due Diligence (OECD Step 4)

Aptiv is an active RMI member serving on several subcommittees and supports smelter audits through the RMAP.

Annual Reporting on Supply Chain Due Diligence (OECD Step 5)

Aptiv's Form SD and CMR are filed annually with the SEC, and a copy of the CMR is publicly available on the Company’s website in the Financial Information section of the Investors page at ir.aptiv.com.

IV. Due Diligence Performance and Results

In accordance with the Rule’s requirements for 3TGs that are, or Aptiv had reason to believe may be, sourced from the Covered Countries, Aptiv was required to exercise due diligence on the source and chain of custody of these identified 3TG's in accordance with a nationally or internationally recognized due diligence framework.

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Aptiv designed its smelter RCOI and due diligence processes in accordance with the applicable sections of Steps 2, 3 and 4 of the OECD Guidance. Based on its assessment of the survey responses received from suppliers as part of its RCOI process, Aptiv performed smelter RCOI and due diligence measures as described below in a manner consistent with the OECD Guidance on the smelters that were identified by our suppliers as potential sources of 3TG in our products.

For each 3TG smelter that was identified by our suppliers as being in Aptiv's supply chain, Aptiv attempted to directly engage the smelter to determine whether or not the smelter sourced from the Covered Countries. For smelters that did not respond to direct engagement, Aptiv reviewed publicly available information to determine if there was any reason to believe that the smelter may have sourced 3TG from the Covered Countries during the reporting period. This information included the most recent report by the United Nations (“U.N.”) Group of Experts on the Democratic Republic of the Congo, publications by non-governmental organizations such as the Enough Project, Global Witness and Radio Okapi (the U.N. funded news organization in the conflict region of the DRC) and a search of other publicly available information. For smelters that declared directly (e.g. through correspondence, publicly available Conflict Minerals policy, or information available on their website), or through their relevant industry association, that they did not source from the Covered Countries, and were not recognized as RMAP Conformant, Aptiv reviewed the publicly available information sources listed above to determine if there was any contrary evidence to the smelter’s declaration.

Due Diligence Results

As a result of these procedures, 46 of the 340 smelters identified by our suppliers either source, or Aptiv had reason to believe they may source, 3TG from the Covered Countries. The countries of origin of 3TG from these 46 smelters may include the DRC, Rwanda, Burundi, Tanzania, Uganda and Zambia. As described above, this assessment was based on information received directly from the smelters, information received through the RMAP and/or the other public information sources listed above.

In accordance with the Rule’s requirements for 3TGs that are, or Aptiv had reason to believe may be, sourced from the Covered Countries, Aptiv was required to exercise due diligence on these minerals’ source and chain of custody. Of these 46 smelters, 36 smelters were conformant with the RMAP and were accordingly listed on the RMI’s website as RMAP Conformant, meaning that the smelters have been determined to be conformant with the RMAP’s, or an equivalent, independent third party audit program.

The following table categorizes the smelters identified by our suppliers as being in our supply chain by 3TG mineral, those identified as sourcing from the Covered Countries and RMAP status:
 Covered Country SourcedNon-Covered Country SourcedTotal Smelters
 RMAP ConformantRMAP ActiveNot RMAP ConformantTotalRMAP ConformantRMAP ActiveNot RMAP ConformantTotal
Tin— — 49 11 14 74 78 
Tantalum19 — — 19 19 — — 19 38 
Tungsten— — 35 43 50 
Gold16 100 52 158 174 
Total36 46 203 22 69 294 340 

All compliance status information in the above table is as of January 20, 2022, and is based solely on information made available by the RMI and listed on the RMI website, without independent verification by us. “Conformant” means that the smelter was listed as conformant with the RMAP assessment protocols. “Active” means that the smelter has committed to undergo an RMAP audit or is participating in one of the cross-recognized certification programs. Smelters not listed as Conformant or Active are classified as “Not Conformant.” Sourcing status information is based on information received directly from the smelters, information received through the RMAP and/or the other public information sources listed above. Included in “Covered Country Sourced” are smelters which Aptiv had reason to believe may source from the Covered Countries, and included in “Non-Covered Country Sourced” are smelters which Aptiv had no reason to believe source from the Covered Countries.

The mines used by these smelters are not publicly available and were not disclosed by these smelters. Through experience gained from participating in the RMI, we have concluded that requiring our suppliers to complete the CMRT and conducting the due diligence process described above represents the most reasonable best effort we can make at this time to identify the mines and countries of origin of 3TGs contained in our products with the greatest possible specificity.

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Risk Mitigation

Aptiv conducted risk mitigation on the smelters that were identified as sourcing, or believed to be sourcing, from the Covered Countries and that were not recognized as RMAP Conformant. Aptiv’s risk mitigation was designed in accordance with Step 3B of the OECD Guidance and was reported to the designated members of senior management that comprise the Conflict Minerals Steering Committee in accordance with Step 3A of the OECD Guidance.

Aptiv conducted risk mitigation on 10 gold smelters that Aptiv had reason to believe may source from the Covered Countries. Based on the information provided by our suppliers, the gold provided by these smelters may have been included in products manufactured in 2021 by at least one of our business segments.

Aptiv’s risk mitigation process included performing additional due diligence to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries. This additional due diligence included further review of the publicly available information sources noted above in order to determine if there was any reason to believe the smelter directly or indirectly financed or benefited armed groups in the Covered Countries, verifying with internal stakeholders and relevant suppliers whether 3TGs from the smelter were actually in Aptiv’s supply chain in the 2021 reporting period and direct engagement with each high risk smelter to verify risk and to encourage the smelter to become RMAP Conformant. As part of our due diligence procedures, we communicated concerns to the applicable suppliers in our supply chain that source from these smelters and encouraged our suppliers to take appropriate action to remove these smelters from their supply chain and to encourage the smelters to become RMAP Conformant.

Continuous Improvement of Supply Chain Due Diligence

The activities undertaken by Aptiv as described in this report have helped to mitigate the risk that the 3TG materials necessary to our products benefited armed groups in the Covered Countries. Going forward, we intend to take the following steps to improve our due diligence process and further mitigate the risk that the 3TG materials necessary to our products benefit armed groups:

Continue to refine the supplier lists from all Aptiv entities to ensure relevant suppliers are included;
Continue to strengthen our engagement with our suppliers regarding Conflict Minerals, and require relevant new suppliers to provide a CMRT;
Continue to expect our suppliers to obtain current, accurate and complete information from their supply chain about their smelters and refiners of Conflict Minerals;
Encourage all smelters identified as a possible part of our supply chain to be audited and certified to a protocol recognized by the RMAP, particularly those which are sourcing, or believed to be sourcing, from the Covered Countries either directly or indirectly through suppliers and/or relevant industry partnerships, including follow-up in 2022 on smelters that required risk mitigation in 2021;
Continue to participate in the AIAG, RMI or other relevant trade associations to define and improve best practices and build leverage over the supply chain in accordance with the OECD Guidance; and
Expand the expected responsible sourcing behavior to all Conflict Affected and High Risk Areas (CAHRAs).

Additional Risk Factors

The statements within this CMR are based on the RCOI process and due diligence performed in good faith by Aptiv, and are based on the information available at the time. A number of factors could introduce errors or otherwise affect the statements made within. These factors include, but are not limited to, gaps in supplier data, gaps in smelter data, errors or omissions in information provided by suppliers, errors or omissions in information provided by smelters, confusion by suppliers over requirements of the SEC final rule, gaps in supplier education and knowledge, errors or omissions in public information, translation of public data, oversights or errors in conflict-free smelter audits, Covered Country-sourced materials being declared secondary materials, illegally tagged Conflict Minerals from Covered Countries being introduced into the supply chain and smuggling of Conflict Minerals from Covered Countries to countries beyond the Covered Countries.
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Appendix to the 2021 Conflict Minerals Report of Aptiv PLC
Processing Facilities Identified in Supplier CMRT Responses

The following table lists the name and 3TG of the processing facilities identified in supplier CMRT responses to Aptiv as part of its 2021 reasonable country of origin inquiry as described in the CMR. All information in the following table is based on information made available by the RMI and listed on the RMI website as of January 20, 2022.
3TG MetalStandard Smelter NameSmelter ID
Gold8853 S.p.A.CID002763
GoldAbington Reldan Metals, LLCCID002708
GoldAdvanced Chemical CompanyCID000015
GoldAfrican Gold RefineryCID003185
GoldAida Chemical Industries Co., Ltd.CID000019
GoldAl Etihad Gold Refinery DMCCCID002560
GoldAlexy MetalsCID003500
GoldAllgemeine Gold-und Silberscheideanstalt A.G.CID000035
GoldAlmalyk Mining and Metallurgical Complex (AMMC)CID000041
GoldAngloGold Ashanti Córrego do Sítio MineraçãoCID000058
GoldArgor-Heraeus S.A.CID000077
GoldAsahi Pretec Corp.CID000082
GoldAsahi Refining Canada Ltd.CID000924
GoldAsahi Refining USA Inc.CID000920
GoldAsaka Riken Co., Ltd.CID000090
GoldAtasay Kuyumculuk Sanayi Ve Ticaret A.S.CID000103
GoldAU Traders and RefinersCID002850
GoldAugmont Enterprises Private Limited
CID003461
GoldAurubis AGCID000113
GoldBangalore RefineryCID002863
GoldBangko Sentral ng Pilipinas (Central Bank of the Philippines)CID000128
GoldBoliden ABCID000157
GoldC. Hafner GmbH + Co. KGCID000176
Gold
C.I Metales Procesados Industriales SAS
CID003421
GoldCaridadCID000180
GoldCCR Refinery - Glencore Canada CorporationCID000185
GoldCendres + Métaux S.A.CID000189
GoldCGR Metalloys Pvt Ltd.CID003382
GoldChimet S.p.A.CID000233
GoldChugai MiningCID000264
GoldDaye Non-Ferrous Metals Mining Ltd.CID000343
GoldDegussa Sonne / Mond Goldhandel GmbHCID002867
GoldDijllah Gold Refinery FZCCID003348
GoldDODUCO Contacts and Refining GmbHCID000362
GoldDowaCID000401
GoldDSC (Do Sung Corporation)CID000359
GoldEco-System Recycling Co., Ltd. East PlantCID000425
GoldEco-System Recycling Co., Ltd. North PlantCID003424
GoldEco-System Recycling Co., Ltd. West PlantCID003425
GoldEmerald Jewel Industry India Limited (Unit 1)CID003487
GoldEmerald Jewel Industry India Limited (Unit 2)CID003488
GoldEmerald Jewel Industry India Limited (Unit 3)CID003489
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GoldEmerald Jewel Industry India Limited (Unit 4)CID003490
GoldEmirates Gold DMCCCID002561
GoldFidelity Printers and Refiners Ltd.CID002515
GoldFujairah Gold FZCCID002584
GoldGCC Gujrat Gold Centre Pvt. Ltd.CID002852
GoldGeib Refining CorporationCID002459
GoldGold Coast Refinery
CID003186
GoldGold Refinery of Zijin Mining Group Co., Ltd.CID002243
GoldGreat Wall Precious Metals Co., Ltd. of CBPMCID001909
GoldGuangdong Jinding Gold LimitedCID002312
GoldGuoda Safina High-Tech Environmental Refinery Co., Ltd.CID000651
GoldHangzhou Fuchunjiang Smelting Co., Ltd.CID000671
GoldHeimerle + Meule GmbHCID000694
GoldHenan Yuguang Gold & Lead Co., Ltd.CID002519
GoldHeraeus Metals Hong Kong Ltd.CID000707
GoldHeraeus Germany GmbH Co. KGCID000711
GoldHunan Chenzhou Mining Co., Ltd.CID000767
GoldHunan Guiyang yinxing Nonferrous Smelting Co., Ltd.CID000773
GoldHwaSeong CJ Co., Ltd.CID000778
GoldIndustrial Refining CompanyCID002587
GoldInner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.CID000801
GoldInternational Precious Metal RefinersCID002562
GoldIshifuku Metal Industry Co., Ltd.CID000807
GoldIstanbul Gold RefineryCID000814
GoldItalpreziosiCID002765
GoldJALAN & Company
CID002893
GoldJapan MintCID000823
GoldJiangxi Copper Co., Ltd.CID000855
Gold
JSC Ekaterinburg Non-Ferrous Metal Processing Plant
CID000927
GoldJSC Novosibirsk RefineryCID000493
GoldJSC UralelectromedCID000929
GoldJX Nippon Mining & Metals Co., Ltd.CID000937
GoldK.A. RasmussenCID003497
GoldKaloti Precious MetalsCID002563
GoldKazakhmys Smelting LLCCID000956
GoldKazzincCID000957
GoldKennecott Utah Copper LLCCID000969
GoldKGHM Polska Miedź Spółka AkcyjnaCID002511
GoldKojima Chemicals Co., Ltd.CID000981
GoldKorea Zinc Co., Ltd.CID002605
Gold
Kundan Care Products Ltd.
CID003463
GoldKyrgyzaltyn JSCCID001029
GoldKyshtym Copper-Electrolytic Plant ZAOCID002865
GoldL'azurde Company For JewelryCID001032
Gold
L'Orfebre S.A.
CID002762
GoldLingbao Gold Co., Ltd.CID001056
GoldLingbao Jinyuan Tonghui Refinery Co., Ltd.CID001058
GoldLS-NIKKO Copper Inc.CID001078
8


Gold
LT Metal Ltd.
CID000689
GoldLuoyang Zijin Yinhui Gold Refinery Co., Ltd.CID001093
GoldMarsam MetalsCID002606
GoldMaterionCID001113
GoldMatsuda Sangyo Co., Ltd.CID001119
GoldMD OverseasCID003548
GoldMetal Concentrators SA (Pty) Ltd.CID003575
GoldMetallix Refining Inc.CID003557
GoldMetalor Technologies (Hong Kong) Ltd.CID001149
GoldMetalor Technologies (Singapore) Pte., Ltd.CID001152
GoldMetalor Technologies (Suzhou) Ltd.CID001147
GoldMetalor Technologies S.A.CID001153
GoldMetalor USA Refining CorporationCID001157
GoldMetalúrgica Met-Mex Peñoles S.A. De C.V.CID001161
GoldMitsubishi Materials CorporationCID001188
GoldMitsui Mining and Smelting Co., Ltd.CID001193
GoldMMTC-PAMP India Pvt., Ltd.CID002509
GoldModeltech Sdn BhdCID002857
GoldMorris and WatsonCID002282
GoldMoscow Special Alloys Processing PlantCID001204
GoldNadir Metal Rafineri San. Ve Tic. A.Ş.CID001220
GoldNavoi Mining and Metallurgical CombinatCID001236
GoldNH Recytech CompanyCID003189
GoldNihon Material Co., Ltd.CID001259
GoldÖgussa Österreichische Gold- und Silber-Scheideanstalt GmbHCID002779
GoldOhura Precious Metal Industry Co., Ltd.CID001325
GoldOJSC “The Gulidov Krasnoyarsk Non-Ferrous Metals Plant” (OJSC Krastsvetmet)CID001326
GoldPAMP S.A.CID001352
GoldPease & CurrenCID002872
GoldPenglai Penggang Gold Industry Co., Ltd.CID001362
GoldPlanta Recuperadora de Metales SpACID002919
GoldPrioksky Plant of Non-Ferrous MetalsCID001386
GoldPT Aneka Tambang (Persero) TbkCID001397
GoldPX Précinox S.A.CID001498
GoldQG Refining, LLCCID003324
GoldRand Refinery (Pty) Ltd.CID001512
GoldRefinery of Seemine Gold Co., Ltd.CID000522
GoldREMONDIS PMR B.V.CID002582
GoldRoyal Canadian MintCID001534
GoldSAAMPCID002761
GoldSabin Metal Corp.CID001546
GoldSafimet S.p.ACID002973
GoldSAFINA A.S.CID002290
GoldSai RefineryCID002853
GoldSamduck Precious MetalsCID001555
GoldSAMWON Metals Corp.CID001562
GoldSancus ZFS (L’Orfebre, SA)CID003529
GoldSAXONIA Edelmetalle GmbHCID002777
9


GoldSellem Industries Ltd.CID003540
GoldSEMPSA Joyería Platería S.A.CID001585
GoldShandong Gold Smelting Co., Ltd.CID001916
GoldShandong Humon Smelting Co., Ltd.CID002525
GoldShandong Tiancheng Biological Gold Industrial Co., Ltd.CID001619
GoldShandong Zhaojin Gold & Silver Refinery Co., Ltd.CID001622
GoldShenzhen Zhonghenglong Real Industry Co., Ltd.CID002527
Gold
Shirpur Gold Refinery Ltd.
CID002588
GoldSichuan Tianze Precious Metals Co., Ltd.CID001736
GoldSingway Technology Co., Ltd.CID002516
GoldSOE Shyolkovsky Factory of Secondary Precious MetalsCID001756
GoldSolar Applied Materials Technology Corp.CID001761
GoldSovereign MetalsCID003383
GoldState Research Institute Center for Physical Sciences and TechnologyCID003153
GoldSudan Gold RefineryCID002567
GoldSumitomo Metal Mining Co., Ltd.CID001798
GoldSungEel HiMetal Co., Ltd.CID002918
GoldSuper Dragon Technology Co., Ltd.CID001810
GoldT.C.A S.p.ACID002580
GoldTanaka Kikinzoku Kogyo K.K.CID001875
GoldTokuriki Honten Co., Ltd.CID001938
GoldTongling Nonferrous Metals Group Co., Ltd.CID001947
GoldTOO Tau-Ken-AltynCID002615
GoldTorecomCID001955
GoldUmicore Precious Metals ThailandCID002314
GoldUmicore S.A. Business Unit Precious Metals RefiningCID001980
GoldUnited Precious Metal Refining, Inc.CID001993
GoldValcambi S.A.CID002003
GoldWEEEREFININGCID003615
GoldWestern Australian Mint (T/a The Perth Mint)CID002030
GoldWIELAND Edelmetalle GmbHCID002778
GoldYamakin Co., Ltd.CID002100
GoldYokohama Metal Co., Ltd.CID002129
GoldYunnan Copper Industry Co., Ltd.CID000197
GoldZhongkuang Gold Industry Co., Ltd.CID002214
GoldZhongyuan Gold Smelter of Zhongjin Gold CorporationCID002224
TantalumAsaka Riken Co., Ltd.CID000092
TantalumChangsha South Tantalum Niobium Co., Ltd.CID000211
TantalumD Block Metals, LLCCID002504
TantalumExotech Inc.CID000456
TantalumF&X Electro-Materials Ltd.CID000460
TantalumFIR Metals & Resource Ltd.CID002505
TantalumGlobal Advanced Metals AizuCID002558
TantalumGlobal Advanced Metals BoyertownCID002557
TantalumH.C. Starck Hermsdorf GmbHCID002547
TantalumH.C. Starck Inc.CID002548
TantalumHengyang King Xing Lifeng New Materials Co., Ltd.CID002492
TantalumJiangxi Dinghai Tantalum & Niobium Co., Ltd.CID002512
10


TantalumJiangxi Tuohong New Raw MaterialCID002842
TantalumJiuJiang JinXin Nonferrous Metals Co., Ltd.CID000914
TantalumJiujiang Tanbre Co., Ltd.CID000917
TantalumJiujiang Zhongao Tantalum & Niobium Co., Ltd.CID002506
TantalumKEMET de MexicoCID002539
TantalumLSM Brasil S.A.CID001076
TantalumMeta MaterialsCID002847
TantalumMetallurgical Products India Pvt., Ltd.CID001163
TantalumMineração Taboca S.A.CID001175
TantalumMitsui Mining & SmeltingCID001192
TantalumNingxia Orient Tantalum Industry Co., Ltd.CID001277
TantalumNPM Silmet ASCID001200
TantalumQuantumCleanCID001508
TantalumResind Indústria e Comércio Ltda.CID002707
TantalumSolikamsk Magnesium Works OAOCID001769
TantalumTaki Chemical Co., Ltd.CID001869
TantalumTANIOBIS Co., Ltd.CID002544
TantalumTANIOBIS GmbHCID002545
TantalumTANIOBIS Japan Co., Ltd.CID002549
TantalumTANIOBIS Smelting GmbH & Co. KGCID002550
TantalumTelex MetalsCID001891
TantalumUlba Metallurgical Plant JSCCID001969
TantalumXIMEI RESOURCES (GUANGDONG) LIMITEDCID000616
TantalumXinXing HaoRong Electronic Material Co., Ltd.CID002508
TantalumYancheng Jinye New Material Technology Co., Ltd.CID003583
TantalumYanling Jincheng Tantalum & Niobium Co., Ltd.
CID001522
TinAlphaCID000292
TinAn Vinh Joint Stock Mineral Processing CompanyCID002703
TinChenzhou Yunxiang Mining and Metallurgy Co., Ltd.CID000228
TinChifeng Dajingzi Tin Industry Co., Ltd.CID003190
TinChina Tin Group Co., Ltd.CID001070
TinCRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil LtdaCID003486
TinCRM SynergiesCID003524
TinCV Ayi JayaCID002570
Tin
CV Venus Inti Perkasa
CID002455
TinDongguan CiEXPO Environmental Engineering Co., Ltd.CID003356
TinDowaCID000402
TinElectro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock CompanyCID002572
TinEM VintoCID000438
TinEstanho de Rondônia S.A.CID000448
TinFabrica Auricchio Industria e Comercio Ltda.CID003582
TinFenix MetalsCID000468
TinGejiu City Fuxiang Industry and Trade Co., Ltd.CID003410
TinGejiu Kai Meng Industry and Trade LLCCID000942
TinGejiu Non-Ferrous Metal Processing Co., Ltd.CID000538
TinGejiu Yunxin Nonferrous Electrolysis Co., Ltd.CID001908
TinGejiu Zili Mining And Metallurgy Co., Ltd.CID000555
TinGuangdong Hanhe Non-Ferrous Metal Co., Ltd.CID003116
11


TinHuiChang Hill Tin Industry Co., Ltd.CID002844
TinJiangxi New Nanshan Technology Ltd.CID001231
Tin
Luna Smelter, Ltd.
CID003387
TinMa'anshan Weitai Tin Co., Ltd.CID003379
TinMagnu's Minerais Metais e Ligas Ltda.CID002468
TinMalaysia Smelting Corporation (MSC)CID001105
TinMelt Metais e Ligas S.A.CID002500
TinMetallic Resources, Inc.CID001142
TinMetallo Belgium N.V.CID002773
TinMetallo Spain S.L.U.CID002774
TinMineração Taboca S.A.CID001173
TinMinsurCID001182
TinMitsubishi Materials CorporationCID001191
TinModeltech Sdn BhdCID002858
TinNghe Tinh Non-Ferrous Metals Joint Stock CompanyCID002573
TinNovosibirsk Processing Plant Ltd.
CID001305
TinO.M. Manufacturing (Thailand) Co., Ltd.CID001314
TinO.M. Manufacturing Philippines, Inc.CID002517
TinOperaciones Metalúrgicas S.A.CID001337
TinPongpipat Company LimitedCID003208
TinPrecious Minerals and Smelting LimitedCID003409
TinPT Aries Kencana SejahteraCID000309
TinPT Artha Cipta LanggengCID001399
TinPT ATD Makmur Mandiri JayaCID002503
TinPT Babel Inti PerkasaCID001402
TinPT Babel Surya Alam LestariCID001406
TinPT Bangka SerumpunCID003205
TinPT Bukit TimahCID001428
TinPT Cipta Persada MuliaCID002696    
TinPT Lautan Harmonis SejahteraCID002870
TinPT Masbro Alam StaniaCID003380
TinPT Menara Cipta MuliaCID002835
TinPT Mitra Stania PrimaCID001453
TinPT Mitra Sukses GlobalindoCID003449
TinPT Prima Timah UtamaCID001458
TinPT Rajawali Rimba PerkasaCID003381
TinPT Rajehan AriqCID002593
TinPT Refined Bangka TinCID001460
TinPT Stanindo Inti Perkasa
CID001468
TinPT Timah NusantaraCID001486
TinPT Timah Tbk KundurCID001477
TinPT Timah Tbk MentokCID001482
TinPT Tinindo Inter NusaCID001490
TinResind Indústria e Comércio Ltda.CID002706
TinRui Da HungCID001539
TinSoft Metais Ltda.CID001758
TinSuper LigasCID002756
TinThai Nguyen Mining and Metallurgy Co., Ltd.CID002834
12


TinThaisarcoCID001898
TinTin Technology & RefiningCID003325
TinTuyen Quang Non-Ferrous Metals Joint Stock CompanyCID002574
TinVQB Mineral and Trading Group JSC
CID002015
TinWhite Solder Metalurgia e Mineração Ltda.CID002036
TinYunnan Chengfeng Non-ferrous Metals Co., Ltd.CID002158
TinYunnan Tin Company LimitedCID002180
TinYunnan Yunfan Non-ferrous Metals Co., Ltd.CID003397
TungstenA.L.M.T. Corp.CID000004
TungstenACL Metais EireliCID002833
TungstenAlbasteel Industria e Comercio de Ligas Para Fundicao Ltd.CID003427
TungstenArtek LLCCID003553
TungstenAsia Tungsten Products Vietnam Ltd.CID002502
TungstenChenzhou Diamond Tungsten Products Co., Ltd.CID002513
TungstenChina Molybdenum Co., Ltd.CID002641
TungstenChongyi Zhangyuan Tungsten Co., Ltd.CID000258
TungstenCNMC (Guangxi) PGMA Co., Ltd.CID000281
TungstenCronimet Brasil LtdaCID003468
TungstenFujian Ganmin RareMetal Co., Ltd.CID003401
TungstenFujian Xinlu TungstenCID003609
TungstenGanzhou Haichuang Tungsten Co., Ltd.CID002645
TungstenGanzhou Huaxing Tungsten Products Co., Ltd.CID000875
TungstenGanzhou Jiangwu Ferrotungsten Co., Ltd.CID002315
TungstenGanzhou Seadragon W & Mo Co., Ltd.CID002494
TungstenGEM Co., Ltd.CID003417
TungstenGlobal Tungsten & Powders Corp.CID000568
TungstenGuangdong Xianglu Tungsten Co., Ltd.CID000218
TungstenH.C. Starck Tungsten GmbHCID002541
TungstenHunan Chenzhou Mining Co., Ltd.CID000766
TungstenHunan Chunchang Nonferrous Metals Co., Ltd.CID000769
TungstenHydrometallurg, JSCCID002649
TungstenJapan New Metals Co., Ltd.CID000825
TungstenJiangwu H.C. Starck Tungsten Products Co., Ltd.CID002551
TungstenJiangxi Gan Bei Tungsten Co., Ltd.CID002321
TungstenJiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd.CID002313
TungstenJiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.CID002318
TungstenJiangxi Xinsheng Tungsten Industry Co., Ltd.CID002317
TungstenJiangxi Yaosheng Tungsten Co., Ltd.CID002316
TungstenJSC “Kirovgrad Hard Alloys Plant”CID003408
TungstenKennametal FallonCID000966
TungstenKennametal HuntsvilleCID000105
TungstenKGETS Co., Ltd.CID003388
TungstenLianyou Metals Co., Ltd.CID003407
TungstenMalipo Haiyu Tungsten Co., Ltd.CID002319
TungstenMasan High-Tech MaterialsCID002543
TungstenMoliren Ltd.CID002845
TungstenNiagara Refining LLCCID002589
TungstenNPP Tyazhmetprom LLCCID003416
13


TungstenOOO “Technolom” 1CID003614
TungstenOOO “Technolom” 2CID003612
TungstenPhilippine Chuangxin Industrial Co., Inc.CID002827
TungstenTANIOBIS Smelting GmbH & Co. KGCID002542
TungstenUnecha Refractory Metals PlantCID002724
TungstenWolfram Bergbau und Hütten AGCID002044
TungstenWoltech Korea Co., Ltd.CID002843
TungstenXiamen Tungsten (H.C.) Co., Ltd.CID002320
TungstenXiamen Tungsten Co., Ltd.CID002082
TungstenXinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd.CID002830


14