DORMAN PRODUCTS, INC.
Conflict Minerals Report
Explanatory Note
This Conflict Minerals Report (the “Report”) of Dorman Products, Inc. (the “Company,” “Dorman,” “we,” “us,” or “our”) has been prepared pursuant to Rule 13p-1 and Form SD (the “Rule”) promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2025 to December 31, 2025 (the “Reporting Period”).
The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products and the minerals specified in the Rule are necessary to the functionality or production of those products. The specified minerals, which are collectively referred to in this report as “Conflict Minerals,” are gold, columbite-tantalite (coltan), cassiterite and wolframite, including their derivatives, which are limited to metallic forms of tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Company and Product Overview
I.Introduction
The Company is one of the leading suppliers of replacement and upgrade parts in the motor vehicle aftermarket industry, serving passenger cars, light-, medium-, and heavy-duty trucks, as well as specialty vehicles, including utility terrain vehicles (UTVs) and all-terrain vehicles (ATVs). During calendar year 2025, many of our products were manufactured in third party vendor facilities (referred to hereafter as “contract manufacturers”) and certain of our products were manufactured or remanufactured by the Company. This Report relates to products (i) for which Conflict Minerals are necessary to the functionality or production of those products, (ii) that were manufactured, remanufactured or contracted for manufacture by Dorman, and (iii) for which the manufacture was completed during calendar year 2025 (the “Covered Products”). We market and sell the Covered Products in three different sectors of the motor vehicle aftermarket industry: light-duty, heavy-duty and specialty vehicle.
The Covered Products include products in the following categories:
•Engine Products, such as intake and exhaust manifolds, oil filters and coolers, fans, thermostat housings, and throttle bodies;
•Undercar Products, including, but not limited to, fluid lines, fluid reservoirs, connectors, 4-wheel drive components and axles, drain plugs, and other engine, transmission, and axle components;
•Steering and Suspension Products, such as control arms, ball joints, tie-rod ends, brake hardware and hydraulics, wheel and axle hardware, suspension arms, knuckles, links, bushings, leaf springs, and other suspension, steering, and brake components;
•Body Products, including, but not limited to, door handles and hinges, window lift motors, window regulators, switches and handles, wiper components, lighting, electrical, and other interior and exterior vehicle body components, including windshields for UTVs;
•Electronics Products, such as new and remanufactured modules, clusters, and sensors; and
•Hardware Products, including, but not limited to, threaded bolts and auto body fasteners, automotive and home electrical wiring components, and other hardware assortments and merchandise.
Certain products we sell contain parts that can be recycled, or, as more commonly referred to in our industry, remanufactured. We refer to the used product that is ultimately remanufactured as core. A used core is remanufactured and sold to the customer as a replacement for a unit on a vehicle. Customers and end-users that purchase a
remanufactured part will generally return the used core to us, which we then use in the remanufacturing process to make another finished good. Our core inventory consists of used cores purchased and held in our facilities, used cores that are in the process of being returned from our customers and end-users, and remanufactured cores held in finished goods inventory at our facilities. Our products that utilize cores include electronic control modules and complex mechatronics. To the extent such cores contain Conflict Minerals, the Conflict Minerals are from scrap/recycled sources, and therefore, no further due diligence is required. To the extent the various additional components, parts or raw materials used to modify the cores contain Conflict Minerals, we generally rely on our vendors of such additional components, parts or raw materials regarding the origin of the Conflict Minerals that are included in such Covered Products.
We do not purchase Conflict Minerals directly from mines or smelters/refiners. The Company’s supply chain with respect to the Covered Products is complex and, often times, there are many parties in the supply chain between the Company and the original source of the Conflict Minerals. Therefore, the Company must rely on its supply chain to provide information regarding the origin of the Conflict Minerals that are included in such Covered Products. We believe that the smelters/refiners of the Conflict Minerals are best suited to identify the sources of such minerals, and we have requested that our vendors take steps to identify the applicable smelters/refiners of the Conflict Minerals in our supply chain.
II. Reasonable Country of Origin Inquiry
The Company conducted a good faith Reasonable Country of Origin Inquiry (“RCOI”) with respect to the Conflict Minerals included in the Covered Products. Such RCOI was reasonably designed to determine whether any of the Conflict Minerals included in the Covered Products may have originated in the Covered Countries and whether any of the Conflict Minerals may be from scrap or recycled sources.
We began this year’s RCOI by using internal product expertise to update our list of products that we manufacture, remanufacture or contract to manufacture which may contain Conflict Minerals. We then identified the names of our largest one hundred and forty-four vendors that accounted for greater than 90% of dollars spent on (i) Covered Products contracted for manufacture by Dorman, and (ii) Conflict Minerals used in the manufacture and remanufacture of Covered Products by Dorman. Once identified, we sent each such vendor a Conflict Minerals reporting template (described below) and a letter with instructions on how to complete the reporting template. We have adopted the Conflict Minerals Reporting Template (the “Template”) developed by the Responsible Minerals Initiative, formerly the Electronic Industry Citizenship Coalition and the Global e-Sustainability Initiative, as a standard questionnaire for conducting inquiries into our vendors’ sources of metals. This Template was created as a common means for the collection of sourcing information related to Conflict Minerals.
In completing the Template, vendors were asked, among other questions, whether the products or components they supplied to us or manufactured for us contained Conflict Minerals; the origin of such Conflict Minerals; to identify the sources of Conflict Minerals from their lower tier level suppliers; to determine the smelter/refiner or mine origin or whether the Conflict Minerals were sourced from scrap or recycled sources. The vendors were asked to return a copy of the Template once completed. Upon return of the Template, responses from vendors were evaluated for completeness, consistency, plausibility, and gaps in information. We received completed Templates from one hundred and thirty-five out of the one hundred and forty-four vendors solicited, accounting for a sum equal to 85% of dollars spent on (i) Covered Products contracted for manufacture by Dorman, and (ii) Conflict Minerals used in the manufacture and remanufacture of Covered Products by Dorman.
After reviewing the results of our RCOI and comparing the smelters/refiners identified in the supply-chain survey against verified lists produced by the Responsible Minerals Initiative (“RMI”), we determined that we had reason to believe that some of the Conflict Minerals necessary for the functionality of our Covered Products may have originated in a Covered Country. Therefore, we determined that the Rule required that we exercise due diligence on the source and chain of custody of such Conflict Minerals.
III. Design of Due Diligence Framework
We designed our due diligence framework to conform in all material respects with the OECD (2016) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition.
IV. Due Diligence Measures Performed by the Company
Our Senior Vice President, Chief Operations Officer oversaw the due diligence measures that we performed for Covered Products. Those measures included, but were not limited to, the following:
•Communicating our Conflict Minerals Policy Statement (the “Conflict Minerals Policy”) to our vendors. A copy of the Company’s Conflict Minerals Policy is available on the Investor Relations portal of www.dormanproducts.com; however, the contents of that site are not incorporated by reference into, and are not otherwise a part of, this Form SD.
•Including contractual provisions in our standard form of vendor agreements requiring applicable vendors (a) to promptly, completely, and accurately respond to all reasonable requests for information made by us with respect to conflict minerals and (b) to only source conflict minerals from “conflict free” smelters identified at http://www.conflictfreesourcing.org/ and certify the same to us upon request.
•Utilizing a Qualification Review Board (the “QRB”), which is an internal cross-functional team that reviewed supplier information and performance to ascertain whether we are partnering with suppliers that meet our high standards and comply with our policies. The QRB reviewed the results of supplier audits and measurements to assure continued compliance with the Company’s expectations.
•Maintaining a multi-disciplinary internal team to implement our Conflict Minerals due diligence measures. Our Conflict Minerals project team was comprised of members of the global trade compliance, quality, supply chain and legal departments who met and/or collaborated at various times during the year to discuss the due diligence process and progress.
•Distributing our Templates to our key suppliers, as discussed in greater detail above.
•Storing our Conflict Minerals records, including all returned Templates, in a web-based application.
•Reporting to senior management on vendors’ responses to our Conflict Minerals information requests.
•Using a third-party service to compare smelters/refiners identified by vendors in their Template responses to the RMI lists of validated conflict free facilities.
Appendix A contains a list of known smelters/refiners reported by the Company’s vendors which have been determined to be legitimate mineral processing operations and may have been used to process the Conflict Minerals utilized in the Covered Products. Based on the information obtained pursuant to the due diligence process, the Company does not have sufficient information with respect to products or components supplied to it or manufactured for it to determine the country of origin of the Conflict Minerals in all Covered Products. At the same time, to the extent that vendors supplied information, the Company received no information from its vendors indicating that the Conflict Minerals in the Company’s Covered Products directly or indirectly financed or benefitted armed groups in the Covered Countries. In some cases, information was provided to us for the entire supply chain of a vendor and was not necessarily limited to facilities that have been confirmed to contribute necessary Conflict Minerals to a Covered Product. Accordingly, we have been unable to definitely link the identified smelters/refiners to only those products/materials in our supply chain; therefore, our smelter/refiner list likely contains more processing facilities than are actually in our supply chain or Covered Products. However, based on the information that was obtained, the Company has reasonably determined that countries of origin of the Conflict Minerals may include the countries listed within Appendix A.
We are a downstream purchaser of Conflict Minerals. Accordingly, the efforts we have undertaken to identify the source and chain of custody of the Conflict Minerals in our Covered Products reflect our circumstances and position in the supply chain. As a result, our inquiry can provide only reasonable, not absolute, assurance regarding the source and chain of custody of the Conflict Minerals necessary to the functionality of the Covered Products. Our process relies on data obtained directly from our vendors who seek similar information within their supply chain to identify the original sources of the necessary Conflict Minerals. Such sources of information may yield inaccurate or incomplete information.
V. Steps to Further Mitigate Risk and Improve Due Diligence in 2026
The Company expects to take the following steps, among others, to improve its due diligence measures and to further mitigate the risk that the necessary Conflict Minerals contained in the Company’s products finance or benefit armed groups in the Covered Countries:
•the Company will continue to engage with vendors in its supply chain to improve the completeness and accuracy of information provided to the Company, including encouraging such vendors to provide product level information to improve the accuracy of information provided to the Company;
•the Company will review changes in vendor circumstances of which it becomes aware that may impact their compliance with the Company’s Conflict Minerals Policy, and in turn may impact the Company’s continued engagement of and relationship with certain vendors;
•the Company will continue to encourage its vendors to take similar measures with their suppliers to ensure alignment with the Company’s sourcing philosophy throughout the supply chain; and
•the Company will continue to encourage its vendors to have only verified “conflict free” sources.
APPENDIX A
SMELTERS/REFINERS
Set forth below are known smelters/refiners reported by the Company’s vendors which may have been used to process the Conflict Minerals utilized in the Covered Products manufactured in calendar year 2025 (“Vendor-Reported Legitimate Facilities”).
Table 1
The following Vendor-Reported Legitimate Facilities achieved during 2025 a Conflict Free designation by the Responsible Minerals Initiative (RMI) or an audit program with which RMI has mutual recognition.
| | | | | |
| Metal | Official 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 | Al Etihad Gold Refinery DMCC |
| 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 | Aurubis AG |
| Gold | Bangalore Refinery |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden Mineral AB (Ronnskar) |
| Gold | C. Hafner GmbH + Co. KG |
| Gold | Cendres + Metaux S.A. |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | Coimpa Industrial LTDA |
| Gold | Daye Non-Ferrous Metals Mining Ltd. |
| 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 | GG Refinery Ltd. |
| Gold | Glencore Canada Corporation - CCR Refinery |
| Gold | Gold by Gold Colombia |
| Gold | Gold Corporation - The Perth Mint |
| | | | | |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Germany GmbH Co. KG |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Impala Platinum - Base Metal Refinery (BMR) |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | International Precious Metal Refiners |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Italpreziosi |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | JX Advanced Metals Corporation |
| Gold | Kazzinc Ltd |
| Gold | Kennecott Utah Copper LLC |
| Gold | KGHM Polska Miedz Spolka Akcyjna |
| Gold | Kojima Chemicals Co., Ltd. |
| Gold | Korea Zinc Co., Ltd. |
| Gold | Kyrgyzaltyn JSC |
| Gold | LS MnM Inc. |
| Gold | LT Metal Ltd. |
| Gold | Materion |
| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | Metal Concentrators SA (Pty) Ltd. |
| 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 | Mitsubishi Materials Corporation |
| Gold | Mitsui Mining and Smelting Co., Ltd. |
| Gold | MKS PAMP SA |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| 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 | Oegussa Oesterreichische Gold- und Silber-Scheideanstalt Gesm.b.H. |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Precinox S.A. |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | REMONDIS PMR B.V. |
| Gold | Royal Canadian Mint |
| Gold | SAAMP |
| | | | | |
| Gold | Safimet S.p.A |
| Gold | SAFINA A.S. |
| Gold | SAM Precious Metals FZ-LLC |
| Gold | SEMPSA Joyeria Plateria S.A. |
| Gold | Shandong Gold Smelting Co., Ltd. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Shenzhen CuiLu Gold Co., Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | T.C.A S.p.A |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Yamakin Co., Ltd. |
| Gold | Yokohama Metal Co., Ltd. |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation |
| Gold | Zijin Mining Group Gold Smelting Co. Ltd. |
| Tantalum | AMG Brasil |
| 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 OU |
| Tantalum | PowerX Ltd. |
| 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 | 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 Synergies EMEA, S.L.U. |
| Tin | CV Ayi Jaya |
| Tin | Dongguan Best Alloys Co., Ltd. |
| Tin | Dowa |
| Tin | EM Vinto |
| Tin | Estanho de Rondonia S.A. |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. |
| Tin | Fenix Metals |
| Tin | Gejiu Non-Ferrous Metal Processing 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 | Luna Smelter, Ltd. |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) |
| Tin | Metallic Resources, Inc. |
| Tin | Mineracao Taboca S.A. |
| Tin | Mining Minerals Resources SARL |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | Operaciones Metalurgicas S.A. |
| Tin | P Kay Metal, Inc |
| Tin | PT Arsed Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | PT Bangka Prima Tin |
| Tin | PT Cipta Persada 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 Rajehan Ariq |
| Tin | PT Timah Tbk Kundur |
| | | | | |
| Tin | PT Timah Tbk Mentok |
| Tin | Resind Industria e Comercio Ltda. |
| Tin | Rui Da Hung |
| 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 | White Solder Metalurgia e Mineracao Ltda. |
| Tin | Woodcross Smelting Company Limited |
| 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 | 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 | 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 | Jing Yuan Tungsten Technology Co., Ltd. |
| Tungsten | KENEE MINING VIETNAM COMPANY LIMITED |
| Tungsten | Kennametal Fallon |
| Tungsten | Kennametal Huntsville |
| 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 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 | Tungamoy Metals Inc. |
| Tungsten | Tungsten Vietnam Joint Stock Company |
| Tungsten | Wolfram Bergbau und Hutten AG |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Xiamen Tungsten Co., Ltd. |
Table 2 – The following Vendor-Reported Legitimate Facilities were validated as smelters/refiners but were unaudited in 2025 by the RMI (or another similar program).
| | | | | |
| Metal | Official Smelter Name |
| Gold | African Gold Refinery |
| Gold | Albino Mountinho Lda. |
| Gold | Alexy Metals |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold | Attero Recycling Pvt Ltd |
| Gold | AU Traders and Refiners |
| Gold | Augmont Enterprises Private Limited |
| Gold | Caridad |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Dijllah Gold Refinery FZC |
| 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 | Emirates Gold DMCC |
| Gold | Fidelity Printers and Refiners Ltd. |
| Gold | Fujairah Gold FZC |
| Gold | Gasabo Gold Refinery Ltd |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. |
| Gold | Gold Coast Refinery |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ CO., LTD. |
| Gold | JALAN & Company |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant |
| Gold | JSC Novosibirsk Refinery |
| Gold | JSC Uralelectromed |
| Gold | K.A. Rasmussen |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kundan Care Products Ltd. |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO |
| Gold | L'azurde Company For Jewelry |
| Gold | Lingbao Gold Co., Ltd. |
| Gold | L'Orfebre S.A. |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. |
| Gold | Marsam Metals |
| Gold | MD Overseas |
| Gold | Metallix Refining Inc. |
| Gold | Minera Titan del Peru SRL (MTP) - Belen Plant |
| Gold | Modeltech Sdn Bhd |
| Gold | Morris and Watson |
| Gold | Moscow Special Alloys Processing Plant |
| Gold | NOBLE METAL SERVICES |
| | | | | |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) |
| Gold | Pease & Curren |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | Prioksky Plant of Non-Ferrous Metals |
| Gold | QG Refining, LLC |
| Gold | Sabin Metal Corp. |
| Gold | Samduck Precious Metals |
| Gold | SAMWON METALS Corp. |
| Gold | Shandong Humon Smelting Co., Ltd. |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. |
| Gold | Shirpur Gold Refinery Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals |
| Gold | Sovereign Metals |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Super Dragon Technology Co., Ltd. |
| Gold | TITAN COMPANY LIMITED, JEWELLERY DIVISION |
| Gold | Tongling Nonferrous Jinguan (Ausmelt) Copper Industry |
| Gold | Torecom |
| Gold | Umicore Precious Metals Thailand |
| Gold | WEEEREFINING |
| Gold | Yunnan Copper Southwest Copper Branch |
| Tantalum | 5D Production OU |
| Tantalum | Jiangxi Suns Nonferrous Materials Co. Ltd. |
| Tantalum | Solikamsk Magnesium Works OAO |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Conecsus LLC |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd |
| Tin | Ma'anshan Weitai Tin Co., Ltd. |
| Tin | Malaysia Smelting Corporation (MSC) |
| Tin | Melt Metais e Ligas S.A. |
| Tin | Modeltech Sdn Bhd |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | Novosibirsk Tin Combine |
| Tin | Precious Minerals and Smelting Limited |
| Tin | PT Masbro Alam Stania |
| | | | | |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company |
| Tin | VQB Mineral and Trading Group JSC |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Hunan Jintai New Material Co., Ltd. |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
| Tungsten | Hydrometallurg, JSC |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" |
| Tungsten | Moliren Ltd. |
| Tungsten | Nam Viet Cromit Joint Stock Company |
| Tungsten | NPP Tyazhmetprom LLC |
| Tungsten | OOO “Technolom” 1 |
| Tungsten | OOO “Technolom” 2 |
| Tungsten | Philippine Carreytech Metal Corp. |
| Tungsten | Unecha Refractory Metals Plant |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. |
Based on the information that was obtained from our suppliers, the Company has reasonably determined that the countries of origin with respect to the Vendor-Reported Legitimate Facilities listed in each of Table 1 and Table 2 may include the following: Angola; Argentina; Armenia; Australia; Austria; Belarus; Bermuda; Bolivia; Brazil; Burundi; Cambodia; Canada; Central African Republic; Chile; China; Colombia; Congo; Democratic Republic of the Congo; Cote D’Ivoire; Czechia; Djibouti; Ecuador; Egypt; Estonia; Ethiopia; Finland; France; Germany; Ghana; Guinea; Hungary; India; Indonesia; Ireland; Israel; Japan; Jersey; Kazakhstan; Kenya; Republic of Korea; Kyrgyzstan; People’s Democratic Republic Laos; Madagascar; Malaysia; Mali; Mexico; Mongolia; Morocco; Mozambique; Myanmar; Namibia; Netherlands; New Zealand; Niger; Nigeria; Papua New Guinea; Peru; Philippines; Poland; Portugal; Russian Federation; Rwanda; Saudi Arabia; Sierra Leone; Singapore; Slovakia; South Africa; South Sudan; Spain; Suriname; Sweden; Switzerland; Taiwan; Tajikistan; United Republic of Tanzania; Thailand; Turkey; Uganda; United Kingdom of Great Britain and Northern Ireland; United States; Uzbekistan; Vietnam; Zambia; and Zimbabwe.