Lumentum Holdings Inc.
Conflict Minerals Report
For the Calendar Year Ended December 31, 2025
Introduction
Lumentum Holdings Inc. (“we”, “our”, “Lumentum” or the “Company”) is an industry-leading provider of optical and photonic products defined by revenue and market share essential to a range of cloud, artificial intelligence and machine learning (“AI/ML”), telecommunications, consumer, and industrial end-market applications.
Prior to July 2025, we operated in two end-market focused reportable segments, Cloud & Networking and Industrial Tech. Our Cloud & Networking products included a comprehensive portfolio of optical and photonic components, modules, and subsystems supplied to cloud and communications network operators and network equipment manufacturers building cloud data center infrastructure, including products for AI/ML and data center interconnect (“DCI”) applications, and communications service provider networks, including products for access (local), metro (intracity), long-haul (city-to-city and worldwide), and submarine (undersea) network infrastructure. Our Cloud & Networking products also supported network equipment manufacturers building enterprise network infrastructure. Demand for our Cloud & Networking products was driven by the rapid growth in cloud and network capacity required for expanding cloud computing and services, including for AI/ML, streaming video and video conferencing, gaming, wireless and mobile devices, and internet of things. Our Industrial Tech products included solid-state lasers, kilowatt-class fiber lasers, diode lasers, ultrafast lasers, and gas lasers, which address applications in numerous end-markets. In the industrial manufacturing end-market, our lasers are incorporated into our customers’ manufacturing machine tools used for the precision processing of materials in a range of industries including semiconductor device and microelectronics fabrication, electric vehicle and battery production, metal cutting and welding, and advanced manufacturing. Our lasers also address certain semiconductor inspection and life-science applications. Our products can also be used in the industrial end-market in imaging and sensing systems for process feedback and control, quality assurance, and waste reduction. Adoption of our products in the industrial end-market is driven by the needs of customers to advance semiconductor and microelectronics industry roadmaps, including those that support cloud data center and AI/ML infrastructure, and by Industry 4.0/5.0 trends, including increasing manufacturing precision and flexibility and reducing waste and environmental impact. Demand for our products in the industrial end-market is driven by end-customer investments in manufacturing capacity. In the consumer end-market, our laser light sources are integrated into our customers’ 3D sensing cameras, which are used in mobile devices and other consumer electronics devices to enable applications including biometric identification, computational photography and virtual and augmented reality. In the automotive end-market, our lasers are used in our customers’ LiDAR and other optical sensor devices, which are being used in advanced driver assistance systems (“ADAS”) and in-cabin driver and occupant monitoring systems.
Starting in July 2025, we implemented a re-organization, and we are now managed as a single, integrated enterprise, with a unified management team overseeing operations across the entire company, rather than through discrete operating segments. We disaggregate revenue by type of product, which are Components and Systems, and by geography. A Components product is defined as one of the individual building blocks that goes into creating a larger solution. It is typically not a complete product on its own but rather a specialized element that enables system functionality. This includes semiconductor laser chips, laser sub-assemblies, line subsystems and wavelength management systems. These are supplied to customers who then integrate them into their own full system solutions. Components represent foundational parts that support or enable that system’s operation and include a comprehensive portfolio of optical and photonic chips, components, laser light sources that are integrated into smartphones, subsystems supplied to cloud data center operators, AI/ML infrastructure providers, and network equipment manufacturer customers who are building cloud data center and network infrastructures. A Systems product is defined as a complete, stand-alone product that delivers full functionality to the end customer. It is typically self-contained and ready to operate within a customer’s network or application environment. This includes optical modules, optical circuit switches, and industrial lasers such as short-pulse solid-state lasers and kilowatt-class fiber lasers. These products integrate multiple technologies and subsystems into a finished solution that directly addresses a customer’s needs. A system represents the end-product that can be deployed and used independently.
Lumentum has a global footprint that enables us to address global market opportunities for our products. Lumentum has manufacturing capabilities and facilities in North America, South America, Asia-Pacific, and Europe, with employees engaged in research and development, administration, manufacturing, support and sales and marketing activities. For more information, please refer to Lumentum’s Annual Report on Form 10-K for the fiscal year ended June 28, 2025, filed with the U.S. Securities and Exchange Commission (“SEC”) on August 19, 2025.
This Report has been prepared in accordance with the requirements of Rule 13p-1 (the “Rule”) and Form SD promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. This Report relates to the process undertaken by Lumentum to exercise due diligence on the source and chain of custody of cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the “Conflict Minerals”) contained in Lumentum products that were manufactured, or contracted to be manufactured, during the calendar year 2025. Third-party
products that Lumentum sells but that it does not manufacture or contract to manufacture are outside the scope of this Report. This Report can be found on our website at www.lumentum.com/investors.
Executive Summary
Lumentum reviewed its supplier base to determine which suppliers were supplying Lumentum with parts or materials that were necessary to the functionality or production of the products we manufactured in calendar year 2025 and contained Conflict Minerals. We then contacted these identified suppliers to complete the Conflict Minerals Reporting Template (‘CMRT”) as part of our reasonable country of origin inquiry (“RCOI”). In connection with the CMRT, these suppliers generally provided us with a list of smelter or refiner names (collectively, “smelters”) that may have provided the Conflict Minerals in the parts or materials provided to us. We do not have a direct contractual or business relationship with these smelters, thus we worked closely with our suppliers-in-scope for our RCOI process. Through the RCOI process, 321 unique smelter entities were identified. Of these 321 smelters, 40 were identified as sourcing (or there was a reason to believe they may be sourcing) from the Democratic Republic of Congo (the “DRC”) or surrounding countries (collectively, the “Covered Countries”). Lumentum’s due diligence review indicates that 31 of the 40 smelters were found to be conformant to a Responsible Minerals Assurance Process (RMAP) as of December 31, 2025. The remaining 9 smelters sourcing from the Covered Countries were reported by a single supplier and were subject to Lumentum’s risk mitigation process described below.
Design of Due Diligence
Lumentum designed its due diligence measures to conform to the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (the “OECD Guidance”). The OECD Guidance sets forth five steps for supply chain due diligence. There is significant overlap between our reasonable country of origin inquiry (“RCOI”) efforts and our due diligence measures performed, both of which are described below.
Management Systems
Lumentum has established a management system for Conflict Minerals. This included the creation of a Conflict Minerals Team comprised of senior leaders from functional areas of Lumentum impacted by Conflict Minerals. This team was created to support supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program. We have a grievance mechanism through which our employees and suppliers can report a violation of our policies and maintain an e-mail address conflictminerals@lumentum.com for suppliers and employees to report violations, ask questions and voice concerns. We established a system of controls over our mineral supply chain, including the RCOI and due diligence procedures described below. All relevant Conflict Minerals data is kept in our internal database system.
Reasonable Country of Origin Inquiry
Lumentum conducted a RCOI that was designed to include all suppliers and original manufacturers that supplied parts or materials that contained Conflict Minerals and were necessary to the functionality or production of the products we manufactured in calendar year 2025. We conducted the RCOI in accordance with the due diligence processes. As part of our RCOI, we contacted approximately 272 in-scope suppliers, representing those most relevant based on spend. Each direct supplier was asked to provide Conflict Minerals data in the Responsible Minerals Initiative (“RMI”) Conflict Minerals Reporting Template (“CMRT”). Greater than 90% of these suppliers responded. Non-responsive suppliers and suppliers with inadequate responses were contacted multiple times. After this RCOI review, 321 smelters were identified as Conflict Minerals smelters consistent with the smelter definitions agreed upon by industry and the audit protocols published by the RMI. After performing a risk assessment on each of the 321 smelters regarding their responses, 40 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the suppliers as well as other public information available at the time. In accordance with the Rule, Lumentum is required to exercise due diligence on the Conflict Minerals’ source and chain of custody and to follow a nationally or internationally recognized due diligence framework.
Conflict Minerals Policy
Lumentum’s Conflict Minerals Policy is publicly available on our website at: https://www.lumentum.com/en/company/sustainability/our-business.
Risk Assessment and Response
Lumentum’s risk assessment plan was designed to define, identify, mitigate, and manage risks. Risks that arise are reported to the designated member of senior management. As described above under Reasonable Country of Origin Inquiry, Lumentum identified the smelters in its supply and performed a risk assessment for 321 smelters. 40 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information obtained directly from the smelters as well as other public information available at the time. Lumentum then compared the
identified smelter list to the list provided by the RMI and for smelters that were not identified as RMAP conformant, Lumentum conducted risk mitigation. 229 of 321 identified smelters (greater than 70%) were RMAP conformant or actively engaged in the RMAP audit process. These smelters were also reviewed against publicly available information to determine if there was any reason to believe that they directly or indirectly finance or benefit armed groups in the Covered Countries.
Due Diligence Results and Ongoing Risk Mitigation Efforts
Smelters
Of the 40 smelters that either confirmed they source Conflict Minerals from the Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, 31 smelters were found to be RMAP conformant and 9 smelters (Al Etihad Gold Refinery DMCC, Augmont Enterprises Private Limited, Dijllah Gold Refinery FZC, Emirates Gold DMCC, Fidelity Printers and Refiners Ltd., Fujairah Gold FZC, International Precious Metal Refiners, SAM Precious Metals FZ-LLC, Shirpur Gold Refinery Ltd.) were not RMAP Conformant at the end of 2025. Accordingly, Lumentum is continuing its risk mitigation efforts in accordance with the OECD Due Diligence Guidance, including engagement with the sole supplier that has reported these 9 smelters in its CMRT, to determine whether these smelters are actually used in the manufacture of products procured by Lumentum. A complete list of the identified smelters likely used in our supply chain is provided in Annex A hereto.
Steps to be Taken to Mitigate Risk
Lumentum is committed to continuous improvement in our due diligence process to further mitigate the risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts require suppliers to provide information that will allow us to evaluate their Conflict Minerals status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from certified smelters when sourcing material from the Covered Countries.
Given that we are a downstream company, many steps removed from the mining or processing of 3TG, and that we do not purchase raw ore or refined 3TG, Lumentum relies on independent third-party audits of smelters and refiners. Lumentum supports such independent third-party audits, including those conducted by the RMAP, through our financial support for the RMI. Lumentum also actively supports the goal of increasing smelter and refiner participation in the RMAP through our participation in the RMI and direct outreach to those smelters and encourage them to participate in the RMAP.
Additional Risk Factors
The statements included in this Conflict Minerals Report are based on the RCOI process and due diligence performed in good faith by Lumentum. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect our determinations regarding the status of our supply chain with respect to Conflict Minerals. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules, (iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) many suppliers and smelters are unfamiliar with the diligence process and information required to be provided due to this new regulation, which could lead to inaccurate responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in smelter audits, (xi) materials sourced from the Covered Countries could inaccurately be declared secondary materials, (xii) illegally tagged Conflict Minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult. This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lumentum’s actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to Conflict Minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and the Lumentum assumes no obligation to update such statements.
Annex A
Smelters and Refineries
Below is a list of the smelters reported to Lumentum as likely in Lumentum’s supply chain as of December 31, 2025.
| | | | | |
| Metal | Smelter Name |
| Gold | Advanced Chemical Company |
| Gold | Aida Chemical Industries Co., Ltd. |
| Gold | Agosi AG |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao |
| Gold | Argor-Heraeus S.A. |
| Gold | ASAHI METALFINE, Inc. |
| Gold | Asaka Riken Co., Ltd. |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. |
| Gold | Aurubis AG, Hamburg |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) |
| Gold | Boliden Mineral AB (Ronnskar) |
| Gold | C. Hafner GmbH + Co. KG |
| Gold | Caridad |
| Gold | Glencore Canada Corporation - CCR Refinery |
| Gold | Cendres + Metaux S.A. |
| Gold | Yunnan Copper Southwest Copper Branch |
| Gold | Chimet S.p.A. |
| Gold | Chugai Mining |
| Gold | DSC (Do Sung Corporation) |
| Gold | Dowa |
| Gold | Eco-System Recycling Co., Ltd. East Plant |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. |
| Gold | LT Metal Ltd. |
| Gold | Heimerle + Meule GmbH |
| Gold | Heraeus Metals Hong Kong Ltd. |
| Gold | Heraeus Germany GmbH Co. KG |
| Gold | Hunan Chenzhou Mining Co., Ltd. |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. |
| Gold | HwaSeong CJ CO., LTD. |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. |
| Gold | Ishifuku Metal Industry Co., Ltd. |
| Gold | Istanbul Gold Refinery |
| Gold | Japan Mint |
| Gold | Jiangxi Copper Co., Ltd. |
| Gold | Asahi Refining USA Inc. |
| Gold | Asahi Refining Canada Ltd. |
| Gold | JX Advanced Metals Corporation |
| Gold | Kazakhmys Smelting LLC |
| Gold | Kazzinc Ltd |
| Gold | Kennecott Utah Copper LLC |
| Gold | Kojima Chemicals Co., Ltd. |
| | | | | |
| Gold | Kyrgyzaltyn JSC |
| Gold | LS MnM Inc. |
| Gold | Materion |
| Gold | Matsuda Sangyo Co., Ltd. |
| Gold | Metalor Technologies (Suzhou) Ltd. |
| Gold | Metalor Technologies (Hong Kong) Ltd. |
| Gold | Metalor Technologies (Singapore) Pte., 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 | Nadir Metal Rafineri San. Ve Tic. A.S. |
| Gold | Navoi Mining and Metallurgical Combinat |
| Gold | Nihon Material Co., Ltd. |
| Gold | Ohura Precious Metal Industry Co., Ltd. |
| Gold | MKS PAMP SA |
| Gold | Penglai Penggang Gold Industry Co., Ltd. |
| Gold | PT Aneka Tambang (Persero) Tbk |
| Gold | PX Precinox S.A. |
| Gold | Rand Refinery (Pty) Ltd. |
| Gold | Royal Canadian Mint |
| Gold | Sabin Metal Corp. |
| Gold | Samduck Precious Metals |
| Gold | Samwon Metals Corp. |
| Gold | SEMPSA Joyeria Plateria S.A. |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. |
| Gold | Solar Applied Materials Technology Corp. |
| Gold | Sumitomo Metal Mining Co., Ltd. |
| Gold | Super Dragon Technology Co., Ltd. |
| Gold | Tanaka Kikinzoku Kogyo K.K. |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM |
| Gold | Shandong Gold Smelting Co., Ltd. |
| Gold | Tokuriki Honten Co., Ltd. |
| Gold | Tongling Nonferrous Jinguan (Ausmelt) Copper Industry |
| Gold | Torecom |
| Gold | Umicore S.A. Business Unit Precious Metals Refining |
| Gold | United Precious Metal Refining, Inc. |
| Gold | Valcambi S.A. |
| Gold | Gold Corporation - The Perth Mint |
| 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. |
| Gold | Morris and Watson |
| | | | | |
| Gold | SAFINA A.S. |
| Gold | Umicore Precious Metals Thailand |
| Gold | MMTC-PAMP India Pvt., Ltd. |
| Gold | KGHM Polska Miedz Spolka Akcyjna |
| Gold | Fidelity Printers and Refiners Ltd. |
| Gold | Singway Technology Co., Ltd. |
| Gold | Shandong Humon Smelting Co., Ltd. |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. |
| Gold | Al Etihad Gold Refinery DMCC |
| Gold | Emirates Gold DMCC |
| Gold | International Precious Metal Refiners |
| Gold | T.C.A S.p.A |
| Gold | REMONDIS PMR B.V. |
| Gold | Fujairah Gold FZC |
| Gold | Shirpur Gold Refinery Ltd. |
| Gold | Korea Zinc Co., Ltd. |
| Gold | Marsam Metals |
| Gold | TOO Tau-Ken-Altyn |
| Gold | Abington Reldan Metals, LLC |
| Gold | Shenzhen CuiLu Gold Co., Ltd. |
| Gold | Albino Mountinho Lda. |
| Gold | SAAMP |
| Gold | L'Orfebre S.A. |
| Gold | 8853 S.p.A. |
| Gold | Italpreziosi |
| Gold | WIELAND Edelmetalle GmbH |
| Gold | Oegussa Oesterreichische Gold- und Silber-Scheideanstalt Gesm.b.H. |
| Gold | AU Traders and Refiners |
| Gold | GGC Gujrat Gold Centre Pvt. Ltd. |
| Gold | Modeltech Sdn Bhd |
| Gold | Bangalore Refinery |
| Gold | Degussa Sonne / Mond Goldhandel GmbH |
| Gold | Pease & Curren |
| Gold | JALAN & Company |
| Gold | SungEel HiMetal Co., Ltd. |
| Gold | Planta Recuperadora de Metales SpA |
| Gold | ABC Refinery Pty Ltd. |
| Gold | Safimet S.p.A |
| Gold | State Research Institute Center for Physical Sciences and Technology |
| Gold | Gold Coast Refinery |
| Gold | NH Recytech Company |
| Gold | QG Refining, LLC |
| Gold | Dijllah Gold Refinery FZC |
| Gold | CGR Metalloys Pvt Ltd. |
| Gold | Sovereign Metals |
| Gold | Eco-System Recycling Co., Ltd. North Plant |
| Gold | Eco-System Recycling Co., Ltd. West Plant |
| | | | | |
| Gold | Augmont Enterprises Private Limited |
| Gold | Kundan Care Products Ltd. |
| Gold | Emerald Jewel Industry India Limited (Unit 1) |
| Gold | Emerald Jewel Industry India Limited (Unit 2) |
| Gold | Emerald Jewel Industry India Limited (Unit 3) |
| Gold | Emerald Jewel Industry India Limited (Unit 4) |
| Gold | K.A. Rasmussen |
| Gold | Alexy Metals |
| Gold | MD Overseas |
| Gold | Metallix Refining Inc. |
| Gold | Metal Concentrators SA (Pty) Ltd. |
| Gold | WEEEREFINING |
| Gold | Gold by Gold Colombia |
| Gold | Dongwu Gold Group |
| Gold | SAM Precious Metals FZ-LLC |
| Gold | Coimpa Industrial LTDA |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. |
| Gold | TITAN COMPANY LIMITED, JEWELLERY DIVISION |
| Gold | GG Refinery Ltd. |
| Gold | Impala Platinum - Base Metal Refinery (BMR) |
| Gold | Impala Platinum - Rustenburg Smelter |
| Gold | SOLEIL METALS (Chala One Plant) |
| Gold | SOLEIL METALS (YAKARI Plant) |
| Gold | Impala Platinum - Platinum Metals Refinery (PMR) |
| Gold | Elite Industech Co., Ltd. |
| Gold | Minera Titan del Peru SRL (MTP) - Belen Plant |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. |
| Tantalum | F&X Electro-Materials Ltd. |
| Tantalum | XIMEI RESOURCES (GUANGDONG) LIMITED |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. |
| Tantalum | Jiujiang Tanbre Co., Ltd. |
| Tantalum | JX Advanced Metals Corporation |
| Tantalum | AMG Brasil |
| Tantalum | Metallurgical Products India Pvt., Ltd. |
| Tantalum | Mineracao Taboca S.A. |
| Tantalum | Mitsui Kinzoku Company, Limited |
| Tantalum | NPM Silmet AS |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. |
| Tantalum | QuantumClean |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. |
| Tantalum | Taki Chemical Co., Ltd. |
| Tantalum | Telex Metals |
| Tantalum | Ulba Metallurgical Plant JSC |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. |
| Tantalum | D Block Metals, LLC |
| Tantalum | FIR Metals & Resource Ltd. |
| | | | | |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. |
| Tantalum | KEMET de Mexico |
| Tantalum | TANIOBIS Co., Ltd. |
| Tantalum | TANIOBIS GmbH |
| Tantalum | QSIL Metals Hermsdorf GmbH |
| Tantalum | Materion Newton Inc. |
| Tantalum | TANIOBIS Japan Co., Ltd. |
| Tantalum | TANIOBIS Smelting GmbH & Co. KG |
| Tantalum | Global Advanced Metals Boyertown |
| Tantalum | Global Advanced Metals Aizu |
| Tantalum | Resind Industria e Comercio Ltda. |
| Tantalum | Jiangxi Tuohong New Raw Material |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd. |
| Tantalum | XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD. |
| Tantalum | PowerX Ltd. |
| Tantalum | CMT Rare Metal Advanced Materials (Hunan) Co., Ltd. |
| Tantalum | Jiangxi Suns Nonferrous Materials Co. Ltd. |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. |
| Tin | Alpha Assembly Solutions Inc |
| Tin | PT Aries Kencana Sejahtera |
| Tin | PT Premium Tin Indonesia |
| Tin | Dongguan Best Alloys Co., Ltd. |
| Tin | Dowa |
| Tin | Empresa Metallurgica Vinto |
| Tin | Estanho de Rondonia S.A. |
| Tin | Feinhutte Halsbrucke GmbH |
| Tin | Fenix Metals |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. |
| Tin | Jean Goldschmidt International (JGI Hydrometal) |
| Tin | Gejiu Kai Meng Industry and Trade LLC |
| Tin | China Tin Group Co., Ltd. |
| Tin | Metallic Resources, Inc. |
| Tin | Mineracao Taboca S.A. |
| Tin | Minsur |
| Tin | Mitsubishi Materials Corporation |
| Tin | Jiangxi New Nanshan Technology Ltd. |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. |
| Tin | Operaciones Metalurgicas S.A. |
| Tin | PT Artha Cipta Langgeng |
| Tin | PT Mitra Stania Prima |
| Tin | PT Prima Timah Utama |
| Tin | PT Refined Bangka Tin |
| Tin | PT Sariwiguna Binasentosa |
| Tin | PT Stanindo Inti Perkasa |
| | | | | |
| Tin | PT Timah Tbk Kundur |
| Tin | PT Timah Tbk Mentok |
| Tin | PT Tinindo Inter Nusa |
| Tin | Rui Da Hung |
| Tin | Soft Metais Ltda. |
| Tin | Thaisarco |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. |
| Tin | VQB Mineral and Trading Group JSC |
| Tin | White Solder Metalurgia e Mineracao Ltda. |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. |
| Tin | Tin Smelting Branch of Yunnan Tin Co., Ltd. |
| Tin | CV Venus Inti Perkasa |
| Tin | Magnu's Minerais Metais e Ligas Ltda. |
| Tin | Melt Metais e Ligas S.A. |
| Tin | PT ATD Makmur Mandiri Jaya |
| Tin | O.M. Manufacturing Philippines, Inc. |
| Tin | CV Ayi Jaya |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company |
| Tin | PT Rajehan Ariq |
| Tin | PT Cipta Persada Mulia |
| Tin | An Vinh Joint Stock Mineral Processing Company |
| Tin | Resind Industria e Comercio Ltda. |
| Tin | Super Ligas |
| Tin | Aurubis Beerse |
| Tin | Aurubis Berango |
| Tin | PT Bangka Prima Tin |
| Tin | HuiChang Hill Tin Industry Co., Ltd. |
| Tin | Modeltech Sdn Bhd |
| Tin | Guangdong Hanhe Non-ferrous Metal Limited Company |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. |
| Tin | Tin Technology & Refining |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. |
| Tin | Ma'anshan Weitai Tin Co., Ltd. |
| Tin | PT Masbro Alam Stania |
| Tin | Luna Smelter, Ltd. |
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd. |
| Tin | Precious Minerals and Smelting Limited |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. |
| Tin | PT Mitra Sukses Globalindo |
| Tin | TRATHO Metal Quimica |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda |
| Tin | CRM Synergies EMEA, S.L.U. |
| Tin | Fabrica Auricchio Industria e Comercio Ltda. |
| Tin | PT Putera Sarana Shakti (PT PSS) |
| Tin | Mining Minerals Resources SARL |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. |
| | | | | |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) |
| Tin | Woodcross Smelting Company Limited |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. |
| Tin | PT Arsed Indonesia |
| Tin | P Kay Metal, Inc |
| Tungsten | A.L.M.T. Corp. |
| Tungsten | Kennametal Huntsville |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. |
| Tungsten | Global Tungsten & Powders LLC |
| Tungsten | Japan New Metals Co., Ltd. |
| Tungsten | Kennametal Fallon |
| Tungsten | Wolfram Bergbau und Hutten AG |
| Tungsten | Xiamen Tungsten Co., Ltd. |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. |
| Tungsten | Asia Tungsten Products Vietnam Ltd. |
| Tungsten | Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch |
| Tungsten | H.C. Starck Tungsten GmbH |
| Tungsten | TANIOBIS Smelting GmbH & Co. KG |
| Tungsten | Masan High-Tech Materials |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. |
| Tungsten | Niagara Refining LLC |
| Tungsten | China Molybdenum Tungsten Co., Ltd. |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. |
| Tungsten | Lianyou Metals Co., Ltd. |
| Tungsten | Hubei Green Tungsten Co., Ltd. |
| Tungsten | Cronimet Brasil Ltda |
| Tungsten | Fujian Xinlu Tungsten Co., Ltd. |
| Tungsten | Tungsten Vietnam Joint Stock Company |
| Tungsten | Plansee Composite Materials GmbH |
| Tungsten | Lianyou Resources Co., Ltd. |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd. |
| Tungsten | KENEE MINING VIETNAM COMPANY LIMITED |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation |
| Tungsten | Jing Yuan Tungsten Technology Co., Ltd. |
| Tungsten | S.P.T. spol.s r.o. |
| Tungsten | Tungamoy Metals Inc. |
40 of the smelters above declared to be sourcing, or there was reason to believe they may be sourcing, from the Covered Countries. Under the Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries and there is no requirement to identify the specific Covered Country by smelter. Given the limitation on the specificity of the smelters’ disclosures, the Covered Countries potentially associated with the reported smelters, based on the available information, were the DRC, Rwanda, Burundi, Tanzania, and Uganda.