UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM SD
Specialized Disclosure Report
KVH Industries, Inc.
(Exact name of registrant as specified in its charter)
| Delaware | 0-28082 | |
(State or other jurisdiction of incorporation or organization) |
(Commission file number) |
50 Enterprise Center, Middletown, RI 02842
(Address of principal executive offices) (Zip code)
Felise Feingold
(401) 847-3327
(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:
| x | Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2023. |
| ¨ | Rule 13q-1 under the Securities Exchange Act (17 CFR 240.13q-1) for the fiscal year ended ____________. |
| Section 1. | Conflict Minerals Disclosure |
KVH Industries, Inc. (“KVH”, “we”, or “our”) is a leading manufacturer of solutions that provide global high-speed Internet, television, and voice services via satellite to mobile users at sea and on land as well as a leading provider of commercially licensed entertainment including news, sports, movies, and music to commercial and leisure customers in the maritime, hotel, and retail markets.
| Item 1.01 | Conflict Minerals Disclosure and Report |
This Form SD is filed pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023.
| Item 1.02 | Exhibit |
KVH’s Conflict Minerals Report is provided as Exhibit 1.01 to this Form SD. A copy of our Conflict Minerals Report may be found at https://ir.kvh.com/financial-information/sec-filings.
| Section 2. | Resource Extraction Issuer Disclosure |
| Item 2.01 | Resource Extraction Issuer Disclosure and Report |
Not applicable.
| Section 3. | Exhibits |
| Item 3.01 | Exhibits |
| Exhibit No. | Description | |
| 1.01 | Conflict Minerals Report of KVH Industries, Inc. |
SIGNATURE
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.
| KVH Industries, Inc. | |||
| (Registrant) | |||
| By: | /s/ Anthony F. Pike | May 31, 2024 | |
| Anthony F. Pike, Chief Financial Officer | (Date) | ||
Exhibit 1.01
KVH Industries, Inc.
CONFLICT MINERALS REPORT
This Conflict Minerals Report of KVH Industries, Inc. (“KVH”, “we”, or “our”) has been prepared pursuant to Rule 13p-1 promulgated under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2023 to December 31, 2023.
Rule 13p-1 and Form SD require companies to disclose certain information regarding products that they manufacture, or contract to manufacture, when: (a) those products contain one or more of the minerals gold, columbite-tantalite (coltan), cassiterite, or wolframite, or their derivatives tantalum, tin, and tungsten (the “Conflict Minerals”); (b) those Conflict Minerals are necessary to the functionality or production of those products; and (c) those Conflict Minerals originated, or may have originated, in the Democratic Republic of the Congo or in a country that shares an internationally recognized border with the Democratic Republic of the Congo (the “Covered Countries”).
Section 1. Product Review and Reasonable Country of Origin Inquiry
Section 1.1 Product Review
KVH conducted an analysis of its product lines and determined that Conflict Minerals are used in its system-level products and components.
Section 1.2 Reasonable Country of Origin Inquiry and Conclusion
KVH’s international supply chain is complex. KVH is several layers removed from the smelters in its supply chain, making it difficult to trace the origin of any Conflict Minerals necessary to the functionality or production of its products.
For our 2023 reasonable country of origin inquiry (“RCOI”), we reviewed our suppliers of direct materials, components and system-level products (collectively referred to as “Supplier Materials”). We generated internal reports analyzing all Supplier Material purchases for 2023 (“Total Supplier Spend”). We then ranked each supplier based on the aggregate Total Supplier Spend. We determined that suppliers with $50,000 or more in Total Supplier Spend accounted for approximately 95% of Total Supplier Spend made by KVH during 2023 and determined that it would be reasonable to concentrate our RCOI efforts on this group of 55 suppliers. We refer to this group of suppliers as our “Primary Suppliers.”
In our RCOI for 2023, we surveyed our Primary Suppliers using a template developed by the Responsible Business Alliance (RBA) and the Global e-Sustainability Initiative (GeSI) (the “Conflict Minerals Reporting Template”). KVH sent the Conflict Minerals Reporting Template to all 55 Primary Suppliers and received 50 responses, which represented approximately 91% of our targeted supplier group and approximately 92% of Total Supplier Spend. We made additional requests for responses from the five Primary Suppliers that did not respond initially, but our efforts were not successful. Of the 50 responses received by KVH, 6 indicated that the Conflict Minerals used in Supplier Materials supplied to KVH came from “conflict-free” sources and furnished a list of their verified smelters; 28 confirmed that no Conflict Minerals were used in the Supplier Materials supplied to KVH; 7 indicated that they were unsure of the origin of the Conflict Minerals in the Supplier Materials that they supplied to us; and 9 indicated that their Supplier Materials contained Conflict Minerals and furnished a list of their smelters, some of which were not verified to be “conflict-free”.
The response rate of our Primary Suppliers decreased from approximately 98% in 2022 to 91% in 2023 and the number of respondents who reported themselves as DRC “conflict-free” decreased. The percentage of the responding Primary Suppliers who reported themselves as DRC “undeterminable” (including the 9 Primary Suppliers who sourced some of their materials from unverified smelters) increased from 20% in 2022 to 32% in 2023. Thus, we concluded that, for 2023, as in prior reporting years, we do not have sufficient information from our suppliers or other sources to determine with specificity the countries of origin of the Conflict Minerals used in our products or whether they are from recycled or scrap sources. Therefore, we cannot exclude the possibility that some of these Conflict Minerals may have originated in the Covered Countries and/or are not from recycled or scrap sources.
Section 2. Due Diligence
KVH’s due diligence efforts related to products: (i) for which Conflict Minerals are necessary to the functionality or production of that product; (ii) that were manufactured, or contracted to be manufactured, by KVH; (iii) for which the manufacture was completed during 2023; and (iv) for which KVH was unable to form the basis for a reasonable belief that none of the Conflict Minerals necessary to the functionality or production of those products originated in a Covered Country. The products, which are hereinafter referred to collectively as the “Covered Products,” include KVH’s mobile satellite communications products and components.
Section 2.1 Design of KVH’s Due Diligence Measures
KVH designed its due diligence measures to conform to the framework set forth in the Organisation for Economic Co-operation and Development Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition, including the related supplements on gold, tin, tantalum and tungsten (the “OECD Guidance”).
Section 2.2 Due Diligence Measures Performed by KVH
The due diligence processes followed by KVH are described below under sub-headings corresponding to the five-step framework of the OECD Guidance.
| 1. | Management Systems |
We previously established and have maintained throughout 2023 internal processes for Conflict Minerals supply chain due diligence and reporting. We have implemented a Conflict Minerals Policy Statement and related procedures to help support our supply chain due diligence efforts and communication processes designed to provide information, including our Conflict Minerals Policy Statement, to our suppliers and to the public. In this regard, our supplier purchase contracts include terms and conditions and other contractual flow-downs requiring supplier cooperation and compliance with KVH’s due diligence efforts. We also maintain a “Supplier Information” web page to facilitate supplier access to important documents, including but not limited to KVH’s Conflicts Minerals Policy Statement, General Terms and Conditions of Purchase and General Supplier Quality Clauses, each of which can be found at http://www.kvh.com/suppliers. Additionally, prior to any engagement with KVH, we generally require all prospective suppliers to (a) provide information about their due diligence program and the steps they have taken to determine whether there are any Conflict Minerals in their supply chain; and (b) submit a completed copy of their latest Conflict Minerals Reporting Template. This information gives our Global Supply Chain team early visibility into the compliance program maturity level and smelter base of prospective vendors before we start to do business with that company.
For 2023, our efforts to identify smelters/refiners in our supply chain was facilitated through the use of due diligence tools created by the Responsible Minerals Initiative (“RMI”) founded by the RBA and GeSI for independent third-party audit information, including the Conflict Minerals Reporting Template. The information furnished by our Primary Suppliers was reviewed and analyzed by our internal team led by KVH’s Director of Global Supply Chain and retained within the company’s document retention system. The data obtained from our Primary Suppliers was vetted by our Global Supply Chain team and then used to generate a comprehensive list of all smelters/refiners that had been identified by our Primary Suppliers, which list was then cross-referenced against information from RMI’s Responsible Minerals Assurance Process (“RMAP”) to help us identify the compliant smelters/refiners and origin of minerals processed.
| 2. | Assessment of Risk in the Supply Chain |
In order to determine the origin of Conflict Minerals in the Covered Products:
| ● | An initial meeting of our Global Supply Chain team was held on April 9, 2023 to review our 2023 annual spending and to determine the parameters of our RCOI for 2023. |
| ● | On or around April 10, 2023, we sent letters to our Primary Suppliers, explaining our conflict minerals disclosure obligations and referring the suppliers to online training materials and instructions, and solicited survey responses using the Conflict Minerals Reporting Template. |
| ● | Having received responses from only 29 of the 55 Primary Suppliers by the end of April 2024, a second meeting of our Global Supply Chain team was held on April 29, 2024, during which team members were tasked with following-up with all non-responsive Primary Suppliers. |
| ● | Over the next 4 weeks, members of KVH’s Global Supply Chain team continued its efforts to contact the remaining Primary Suppliers, and by May 29, 2024, KVH had received responses from 50 of the 55 Primary Suppliers. Of the 50 respondents, 43 returned the Conflict Minerals Reporting Template and 7 provided a separate company statement regarding conflict minerals. |
| ● | Having received responses from approximately 91% of our Primary Suppliers, which represented approximately 92% of Total Supplier Spend for 2023, KVH then reviewed the responses and followed up on any incomplete or ambiguous responses. |
| ● | Our Global Supply Chain team then compared the smelters/refiners identified by its Primary Suppliers against the list of facilities that have received a “conformant” designation from the RMI’s RMAP, which designations provide country of origin and due diligence information on the Conflict Minerals sourced by such facilities. |
| 3. | Strategies to Respond to Identified Risks |
KVH’s due diligence efforts are an evolving process that we strive to improve by: (i) maintaining a supplier onboarding process that solicits information about sourcing of conflict minerals, (ii) focusing on the reliability and quality of the information received from our Primary Suppliers; (iii) reviewing responses and following up on incomplete, inaccurate or ambiguous data; (iv) contacting Primary Suppliers who have consistently reported products to be “DRC conflict undeterminable” or the equivalent to determine what steps they have taken to improve their due diligence processes; and (v) maintaining internal processes designed to emphasize the importance of supplier cooperation and compliance with our Conflict Minerals Policy Statement through readily accessible policies and contractual flow-down clauses governing the business relationship, which not only provide us with leverage to promote compliance but also the flexibility needed to reassess and/or terminate certain relationships, as appropriate.
| 4. | Independent Third-Party Audits |
As a result of KVH’s position in the supply chain, there are generally several tiers of suppliers between KVH and the smelters/refiners in our supply chain, and therefore we do not conduct or commission independent third-party audits of the smelters and refiners from which our Primary Suppliers source Conflict Minerals. KVH has relied upon industry initiatives, including the RMI’s RMAP, for independent third-party audit information.
| 5. | Reporting |
With the preparation and submission of this Conflict Minerals Report, KVH has provided a public report of its due diligence measures with regard to the sourcing of Conflict Minerals. A copy of this report is available at https://ir.kvh.com/financial-information/sec-filings.
Section 3. Results of Due Diligence
The response rate among our Primary Suppliers in 2023 was 91%. Among the responses, some of our Primary Suppliers were unable to identify any of the smelters or refiners used in the Supplier Materials supplied to us and certain responses also included names of smelters or refiners that we believe may have been incomplete or misidentified. Such names have not been included among the list of smelters and refiners identified by our Primary Suppliers in Annex 1 below.
In total, we identified approximately 503 smelters as potential sources of Conflict Minerals that were reported to be in the supply chain at some point during the 2023 calendar year. The table below presents the total number of identified smelters or refiners for each mineral and the corresponding percentage of each group that we have been able to verify as conflict-free according to information provided on the RMI website.
| Metal | Total Number of Identified Smelters for Each Metal | Identified Smelters or Refiners Verified or certified as RMAP Conformant | ||||||
| Gold | 221 | 36 | % | |||||
| Tantalum | 51 | 59 | % | |||||
| Tin | 157 | 38 | % | |||||
| Tungsten | 74 | 41 | % | |||||
For the Conflict Minerals contained in the Covered Products, KVH’s due diligence efforts failed to clarify whether the Conflict Minerals contained in those products may have originated in a Covered Country or came from recycled or scrap sources. Nine Primary Suppliers identified seven smelters in their supply chains that KVH believes to be higher risk based on publicly available information regarding their location, namely:
| Mineral | Smelter | Location | ||
| Gold | African Gold Refinery | Uganda | ||
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe | ||
| Gold | GG Refinery Ltd. | United Republic of Tanzania | ||
| Gold | Universal Precious Metals Refining Zambia | Zambia | ||
| Tin | Mining Minerals Resources SARL | Republic of Congo | ||
| Tin | Luna Smelter, Ltd. | Rwanda | ||
| Tantalum | PowerX Ltd. | Rwanda |
RMI identified Mining Minerals Resources SARL of the Republic of Congo and Luna Smelter, Ltd. and PowerX Ltd. of Rwanda as “conformant” smelters.
Our Global Supply Chain team previously contacted the Primary Suppliers who identified the smelters listed above to confirm what efforts each has taken either to certify its smelters or to identify alternate sources. Each of the Primary Suppliers informed KVH that they do not directly purchase materials from any of the smelters listed above and that they were either (i) downstream distributors of components and/or (ii) engaged as build-to-print contract manufacturers who do not choose the components. Consequently, as in prior reporting years, we were unable to validate that any of the smelters or refiners identified by our Primary Suppliers, including the smelters identified above, are actually in our supply chain. We will continue to follow our risk-mitigation processes first implemented in 2019 to help identify possible higher-risk suppliers prior to engagement, and we intend to contact any new suppliers who identify higher-risk smelters such as these to confirm what efforts they have taken either to certify their smelters or to identify alternate sources, if necessary.
Based on our due diligence efforts, KVH has concluded that we do not have sufficient information to determine with specificity the country of origin of all of the Conflict Minerals in our Covered Products or to determine whether the Conflict Minerals were from recycled or scrap sources. Based on the information received from our Primary Suppliers, KVH believes that the facilities that may have been used to process Conflict Minerals in our Covered Products include the smelters and refiners listed in Annex 1 below.
As noted above, certain of our suppliers identified African Gold Refinery as a smelter in their supply chains. We understand that African Gold Refinery was sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control on March 17, 2022. KVH has no direct business with African Gold Refinery. However, given the responses by its suppliers, as part of the escalation process, KVH contacted the suppliers that identified African Gold Refinery as a smelter in their supply chains to request additional information regarding whether African Gold Refinery is actually in their supply chains as relevant to KVH. In response, certain suppliers notified us that they are not able to determine whether African Gold Refinery is in the KVH supply chain as a smelter given the complexity of the supply chain for the nature of the products. Accordingly, KVH has no basis to conclude affirmatively that African Gold Refinery is in its supply chain. KVH is continuing this review and will take appropriate steps regarding its supply chain as needed in connection with that review. KVH is committed to acting in full compliance with the U.S. sanctions, including in connection with its supply chain.
Section 4. Future Steps to Improve Due Diligence
In February 2024, KVH announced a staged wind-down of its manufacturing operations at its Middletown, Rhode Island facility. KVH expects that it will cease substantially all manufacturing activity by the end of 2024. As a result, KVH plans to reassess whether, as of December 31, 2024, it manufactures or contracts to manufacture any products. If not, KVH would expect to file a Form SD with respect to the year ending December 31, 2024 but not for periods thereafter.
In order to improve our due diligence process and compliance efforts during the portion of 2024 that it continues to manufacture or contract to manufacture products, KVH intends to continue to:
| ● | gather additional information which will assist us in determining whether the Conflict Minerals we utilize benefit armed groups contributing to human rights violations; |
| ● | collect and evaluate supplier responses and follow-up with those suppliers that we have deemed to be a higher risk due to incomplete or ambiguous responses; and |
| ● | review, and, if necessary, reassess supplier relationships based on information and resources provided by third-party conflict minerals audit programs such as the RMI’s RMAP and other industry initiatives promoting responsible mineral sourcing practices. |
During the period that KVH continues to manufacture or contract to manufacture products, KVH will continue to expect our suppliers to reasonably assure us that the minerals in the products they supply are conflict-free.
Section 5. Forward Looking Statements
This report includes forward-looking statements that involve risks and uncertainties, including for example statements regarding our due diligence processes with respect to Conflict Minerals. Forward-looking statements are not guarantees of future performance. KVH assumes no obligation to revise or update any forward-looking statements for any reason, except as required by law.
Annex 1
* Denotes smelters/ refiners that received a “conflict-free” designation from an independent third-party audit program, as of May 29, 2024.
| Metal | Smelter or Refiner Name | Country |
| Gold | 8853 S.p.A. | Italy |
| Gold | ABC Refinery Pty Ltd. | Australia |
| Gold | Abington Reldan Metals, LLC* | United States of America |
| Gold | Advanced Chemical Company | United States of America |
| Gold | African Gold Refinery | Uganda |
| Gold | Agosi AG* | Germany |
| Gold | Aida Chemical Industries Co., Ltd.* | Japan |
| Gold | AKITA Seiren | Japan |
| Gold | Al Etihad Gold LLC | United Arab Emirates |
| Gold | Al Ghaith Gold | United Arab Emirates |
| Gold | Albino Mountinho Lda. | Portugal |
| Gold | Alexy Metals | United States of America |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC)* | Uzbekistan |
| Gold | Amagasaki Factory, Hyogo Prefecture, Japan | Japan |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao* | Brazil |
| Gold | Anhui Tongling Nonferrous Metal Mining Co., Ltd. | China |
| Gold | Argor-Heraeus S.A.* | Switzerland |
| Gold | ARY Aurum Plus | United Arab Emirates |
| Gold | Asahi Refining USA Inc.* | United States of America |
| Gold | Asaka Riken Co., Ltd.* | Japan |
| Gold | ATAkulche | Turkey |
| Gold | Attero Recycling Pvt Ltd | India |
| Gold | AU Traders and Refiners | South Africa |
| Gold | Augmont Enterprises Private Limited | India |
| Gold | Aurubis AG* | Germany |
| Gold | Bangalore Refinery | India |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines)* | Philippines |
| Gold | Boliden AB*1 | Sweden |
| Gold | C. Hafner GmbH + Co. KG* | Germany |
| Gold | C.I Metales Procesados Industriales SAS | Colombia |
| Gold | Caridad | Mexico |
| Gold | CCR Refinery - Glencore Canada Corporation* | Canada |
1 This smelter has the same identification number as the entity identified by RMI as “Boliden Ronnskar,” a conformant smelter.
| Gold | Cendres + Metaux S.A. | Switzerland |
| Gold | CGR Metalloys Pvt Ltd. | India |
| Gold | Chala One Plant | Peru |
| Gold | CHALCO Yunnan Copper Co. Ltd. | China |
| Gold | Chimet S.p.A.* | Italy |
| Gold | China Henan Zhongyuan Gold Smelter | China |
| Gold | China's Shandong Gold Mining Co., Ltd | China |
| Gold | Chugai Mining* | Japan |
| Gold | Coimpa Industrial LTDA* | Brazil |
| Gold | Daejin Indus Co., Ltd. | Republic of Korea |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | China |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | Germany |
| Gold | Dijllah Gold Refinery FZC | United Arab Emirates |
| Gold | Do Sung Corporation* | Republic of Korea |
| Gold | DODUCO Contacts and Refining GmbH | Germany |
| Gold | Dongwu Gold Group | China |
| Gold | DS PRETECH Co., Ltd. | Republic of Korea |
| Gold | Eco-System Recycling Co., Ltd.*2 | Japan |
| Gold | Eco-System Recycling Co., Ltd. North Plant* | Japan |
| Gold | Eco-System Recycling Co., Ltd. West Plant* | Japan |
| Gold | Ekaterinburg | Russian Federation |
| Gold | Elemetal Refining, LLC | United States of America |
| Gold | Elite Industech Co., Ltd. | Taiwan |
| Gold | EMC Green Group S.A. | Peru |
| Gold | Emerald Jewel Industry India Limited (Unit 1) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 2) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 3) | India |
| Gold | Emerald Jewel Industry India Limited (Unit 4) | India |
| Gold | Emirates Gold DMCC | United Arab Emirates |
| Gold | Federal State Unitary Enterprise Moscow Special Processing Plant (FSUE MZSS) | Russian Federation |
| Gold | Fidelity Printers and Refiners Ltd. | Zimbabwe |
| Gold | FSE Novosibirsk Refinery | Russian Federation |
| Gold | Fujairah Gold FZC | United Arab Emirates |
| Gold | Fujian Zijin mining stock company gold smelter | China |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | India |
| Gold | Geib Refining Corporation | United States of America |
2 This smelter has the same identification number as the entity identified by RMI as “Eco-System Recycling Co., Ltd. East Plant,” a conformant smelter.
| Gold | GG Refinery Ltd. | United Republic of Tanzania |
| Gold | Gold by Gold Colombia* | Colombia |
| Gold | Gold Coast Refinery | Ghana |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | China |
| Gold | Guangdong Gaoyao Co | China |
| Gold | Guangdong Hua Jian Trade Co., Ltd. | China |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | China |
| Gold | Hang Seng Technology | China |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | China |
| Gold | HeeSung Metal Ltd. | Republic of Korea |
| Gold | Heimerle + Meule GmbH* | Germany |
| Gold | Henan Yuguang Gold & Lead Co., Ltd. | China |
| Gold | Heraeus Germany GmbH Co. KG* | Germany |
| Gold | Heraeus Ltd. Hong Kong* | China |
| Gold | Hunan Chenzhou Mining Group Co., Ltd. | China |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | China |
| Gold | Hung Cheong Metal Manufacturing Limited | China |
| Gold | HwaSeong CJ CO., LTD. | Republic of Korea |
| Gold | Impala Refineries – Base Metals Refinery (BMR) | South Africa |
| Gold | Impala Refineries – Platinum Metals Refinery (PMR) | South Africa |
| Gold | Impala Rustenburg | South Africa |
| Gold | Industrial Refining Company | Belgium |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.* | China |
| Gold | International Precious Metal Refiners | United Arab Emirates |
| Gold | Ishifuku Metal Industry Co., Ltd.* | Japan |
| Gold | Istanbul Gold Refinery* | Turkey |
| Gold | Italpreziosi* | Italy |
| Gold | JALAN & Company | India |
| Gold | Japan Mint* | Japan |
| Gold | JCC*3 | China |
| Gold | Jinlong Copper Co., Ltd. | China |
| Gold | Johnson Matthey Limited | Canada |
| Gold | JSC Uralelectromed | Russian Federation |
| Gold | JX Nippon Mining & Metals Co., Ltd.* | Japan |
| Gold | K.A. Rasmussen | Norway |
| Gold | Kaloti Precious Metals | United Arab Emirates |
| Gold | Kazakhmys Smelting LLC | Kazakhstan |
3 This smelter has the same identification number as the entity identified by RMI as “Jiangxi Copper Co., Ltd.,” a conformant smelter.
| Gold | Kazzinc* | Kazakhstan |
| Gold | Kennecott Utah Copper LLC* | United States of America |
| Gold | KGHM Polska Miedz Spolka Akcyjna* | Poland |
| Gold | Kochi daiicihi Yamaminami plant | Japan |
| Gold | Kojima Chemicals Co., Ltd.* | Japan |
| Gold | Korea Zinc Co., Ltd.* | Republic of Korea |
| Gold | Kundan Care Products Ltd. | India |
| Gold | Kyrgyzaltyn JSC | Kyrgyzstan |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | Russian Federation |
| Gold | L'azurde Company For Jewelry | Saudi Arabia |
| Gold | Lingbao Gold Co., Ltd. | China |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | China |
| Gold | L'Orfebre S.A.* | Andorra |
| Gold | LS MnM Inc.* | Republic of Korea |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | China |
| Gold | Marsam Metals | Brazil |
| Gold | Materion* | United States of America |
| Gold | Matsuda Sangyo Co., Ltd.* | Japan |
| Gold | MD Overseas | India |
| Gold | MEM(Sumitomo Group) | Japan |
| Gold | Metal Concentrators SA (Pty) Ltd.* | South Africa |
| Gold | Metalurgica Met-Mex Penoles, S.A. de C.V* | Mexico |
| Gold | Metallix Refining Inc. | United States of America |
| Gold | Metallurgie Hoboken Overpelt | Belgium |
| Gold | Metalor Switzerland*4 | Switzerland |
| Gold | Metalor Technologies (Hong Kong) Ltd.* | China |
| Gold | Metalor Technologies (Singapore) Pte., Ltd.* | Singapore |
| Gold | Metalor Technologies (Suzhou) Ltd.* | China |
| Gold | Metalor USA Refining Corporation* | United States of America |
| Gold | Mitsubishi Materials Corporation* | Japan |
| Gold | Mitsui Kinzoku Co., Ltd.*5 | Japan |
| Gold | MKS PAMP SA* | Switzerland |
| Gold | MMTC-PAMP India Pvt., Ltd.* | India |
| Gold | Modeltech Sdn Bhd | Malaysia |
| Gold | Morris and Watson | New Zealand |
4 This smelter has the same identification number as the entity identified by RMI as “Metalor Technologies S.A.,” a conformant smelter.
5 This smelter has the same identification number as the entity identified by RMI as “Mitsui Mining and Smelting Co., Ltd.,” a conformant smelter.
| Gold | Morris and Watson Gold Coast | Australia |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S.* | Turkey |
| Gold | Navoi Mining and Metallurgical Combinat* | Uzbekistan |
| Gold | NH Recytech Company* | Republic of Korea |
| Gold | Nihon Material Co., Ltd.* | Japan |
| Gold | NOBLE METAL SERVICES | United States of America |
| Gold | Nyrstar Metals | United States of America |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH* | Austria |
| Gold | Ohura Precious Metal Industry Co., Ltd.* | Japan |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | Russian Federation |
| Gold | Pease & Curren | United States of America |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | China |
| Gold | Planta Recuperadora de Metales SpA* | Chile |
| Gold | Prioksky Plant of Non-Ferrous Metals | Russian Federation |
| Gold | PT Aneka Tambang (Persero) Tbk* | Indonesia |
| Gold | PX Precinox S.A.* | Switzerland |
| Gold | QG Refining, LLC | United States of America |
| Gold | Rand Refinery (Pty) Ltd.* | South Africa |
| Gold | Refinery of Seemine Gold Co., Ltd. | China |
| Gold | Remondis Argentia B.V.* | Netherlands |
| Gold | Republic Metals Corporation | United States of America |
| Gold | Royal Canadian Mint* | Canada |
| Gold | SAAMP | France |
| Gold | Sabin Metal Corp. | United States of America |
| Gold | Safimet S.p.A | Italy |
| Gold | SAFINA A.S.* | Czechia |
| Gold | Sai Refinery | India |
| Gold | Sam Precious Metals | United Arab Emirates |
| Gold | Samdok Metal | Republic of Korea |
| Gold | Samwon Metals Corp. | Republic of Korea |
| Gold | Sancus ZFS (L’Orfebre, SA) | Colombia |
| Gold | SAXONIA Edelmetalle GmbH | Germany |
| Gold | Schone Edelmetaal B.V. | Netherlands |
| Gold | Sellem Industries Ltd. | Mauritania |
| Gold | SEMPSA Joyeria Plateria S.A.* | Spain |
| Gold | Shan Tou Shi Yong Yuan Jin Shu Zai Sheng Co., Ltd. | China |
| Gold | Shandong Hengbang Smelter Co., Ltd. | China |
| Gold | Shandong Humon Smelting Co., Ltd. | China |
| Gold | Shandong Tarzan Bio-Gold Industry Co., Ltd. | China |
| Gold | Shandong Yanggu Xiangguang Co., Ltd. | China |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd.* | China |
| Gold | Shenzhen CuiLu Gold Co., Ltd. | China |
| Gold | Shenzhen Heng Zhong Industry Co., Ltd. | China |
| Gold | SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD. | China |
| Gold | Shenzhen Zhonghenglong Real Industry Co., Ltd. | China |
| Gold | Shirpur Gold Refinery Ltd. | India |
| Gold | Shyolkovsky | Russian Federation |
| Gold | Sichuan Tianze Precious Metals Co., Ltd.* | China |
| Gold | Singway Technology Co., Ltd. | Taiwan |
| Gold | Sino-Platinum Metals Co., Ltd. | China |
| Gold | Solar Applied Materials Technology Corp.* | Taiwan |
| Gold | Sovereign Metals | India |
| Gold | State Research Institute Center for Physical Sciences and Technology | Lithuania |
| Gold | Sudan Gold Refinery | Sudan |
| Gold | SungEel HiMetal Co., Ltd.* | Republic of Korea |
| Gold | Super Dragon Technology Co., Ltd. | China |
| Gold | T.C.A S.p.A* | Italy |
| Gold | Tanaka Denshi Kogyo K.K.*6 | Japan |
| Gold | Tokuriki Honten Co., Ltd.* | Japan |
| Gold | TOO Tau-Ken-Altyn* | Kazakhstan |
| Gold | Torecom* | Republic of Korea |
| Gold | TSK Pretech | Republic of Korea |
| Gold | Umicore Brasil Ltda. | Brazil |
| Gold | Umicore Precious Metals Thailand | Thailand |
| Gold | United Precious Metal Refining, Inc.* | United States of America |
| Gold | Universal Precious Metals Refining Zambia | Zambia |
| Gold | Valcambi S.A.* | Switzerland |
| Gold | Value Trading | Belgium |
| Gold | Viagra Di precious metals (Zhaoyuan) Co., Ltd. | China |
| Gold | WEEEREFINING* | France |
| Gold | Western Australian Mint (The Perth Mint)* | Australia |
| Gold | WIELAND Edelmetalle GmbH* | Germany |
| Gold | Wuzhong Group | China |
| Gold | Yokohama Metal Co., Ltd.* | Japan |
| Gold | Yunnan Gold Mining Group Co., Ltd. (YGMG) | China |
6 This smelter has the same identification number as the entity identified by RMI as “Tanaka Kikinzoku Kogyo K.K.,” a conformant smelter.
| Gold | Zhe Jiang Guang Yuan Noble Metal Smelting Factory | China |
| Gold | Zhongkuang Gold Industry Co., Ltd. | China |
| Gold | Zhongshan Hyper-Toxic Substance Monopolized Co., Ltd. | China |
| Gold | Zhongshan Poison Material Proprietary Co., Ltd. | China |
| Gold | Zhuhai toxic materials Monopoly Ltd. | China |
| Gold | Zhuzhou Smelting Group Co., Ltd | China |
| Tantalum | 5D Production OU | Estonia |
| Tantalum | AMG Brasil* | Brazil |
| Tantalum | ANHUI HERRMAN IMPEX CO. | China |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd.* | China |
| Tantalum | Conghua Tantalum and Niobium Smeltry | China |
| Tantalum | CP Metals Inc. | United States of America |
| Tantalum | D Block Metals, LLC* | United States of America |
| Tantalum | Duoluoshan | China |
| Tantalum | Exotech Inc. | United States of America |
| Tantalum | F&X Electro-Materials Ltd.* | China |
| Tantalum | FIR Metals & Resource Ltd.* | China |
| Tantalum | Global Advanced Metals Aizu* | Japan |
| Tantalum | Global Advanced Metals Boyertown* | United States of America |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | China |
| Tantalum | H.C. Starck Co., Ltd. | Thailand |
| Tantalum | H.C. Starck Hermsdorf GmbH | Germany |
| Tantalum | H.C. Starck Inc. | United States of America |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | Germany |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | Germany |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd.* | China |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd.* | China |
| Tantalum | Jiangxi Tuohong New Raw Material* | China |
| Tantalum | Jiujiang Janny New Material Co., Ltd.* | China |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd.* | China |
| Tantalum | Jiujiang Nonferrous Metals Smelting Company Limited*7 | China |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd.* | China |
| Tantalum | KEMET Blue Metals*8 | Mexico |
| Tantalum | KEMET Blue Powder | United States of America |
7 This smelter has the same identification number as the entity identified by RMI as “Jiujiang Tanbre Co., Ltd.,” a conformant smelter.
8 This smelter has the same identification number as the entity identified by RMI as “KEMET de Mexico,” a conformant smelter.
| Tantalum | Meta Materials | Republic of North Macedonia |
| Tantalum | Metallurgical Products India Pvt. Ltd. (MPIL)* | India |
| Tantalum | Mitsui Mining & Smelting* | Japan |
| Tantalum | Molycorp Silmet A.S. | Estonia |
| Tantalum | Ningxia Non-Ferrous Metal Smeltery*9 | China |
| Tantalum | Plansee SE Reutte | Austria |
| Tantalum | PowerX Ltd.* | Rwanda |
| Tantalum | QuantumClean* | United States of America |
| Tantalum | Resind Ind e Com Ltda.* | Brazil |
| Tantalum | RFH | China |
| Tantalum | RFH Metals & Chemicals Co., Ltd.*10 | China |
| Tantalum | RFH Yancheng Jinye New Material Technology Co., Ltd.* | China |
| Tantalum | Solikamsk | Russian Federation |
| Tantalum | Taike Technology (Suzhou) Co.,Ltd. | China |
| Tantalum | Taki Chemical Co., Ltd.* | Japan |
| Tantalum | TANIOBIS Japan Co., Ltd.* | Japan |
| Tantalum | Telex Metals* | United States of America |
| Tantalum | Ulba Metallurgical Plant JSC* | Kazakhstan |
| Tantalum | V&D New Materials (Jiangsu) Co., Ltd.* | China |
| Tantalum | XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD.* | China |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd.* | China |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | China |
| Tantalum | Zhuzhou Cemented Carbide Group Co., Ltd. | China |
| Tin | Alent plc | United States of America |
| Tin | An Vinh Joint Stock Mineral Processing Company | Vietnam |
| Tin | Aurubis Beerse* | Belgium |
| Tin | Aurubis Berango* | Spain |
| Tin | Brand IMLI | Indonesia |
| Tin | Brand RBT | Indonesia |
| Tin | Chengfeng Metals Co Pte Ltd | China |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.* | China |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd.* | China |
9 This smelter has the same identification number as the entity identified by RMI as “Ningxia Orient Tantalum Industry Co., Ltd.,” a conformant smelter.
10 This smelter has the same identification number as the entity identified by RMI as “RFH Recycling Metals Co., Ltd.,” a conformant smelter.
| Tin | China Tin (Hechi)*11 | China |
| Tin | China Yunnan Tin Co Ltd. | China |
| Tin | Chofu Works | Japan |
| Tin | CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda* | Brazil |
| Tin | CRM Synergies* | Spain |
| Tin | CV Ayi Jaya* | Indonesia |
| Tin | CV Dua Sekawan | Indonesia |
| Tin | CV Gita Pesona | Indonesia |
| Tin | CV Nurjanah | Indonesia |
| Tin | CV Serumpun Sebalai | Indonesia |
| Tin | CV Tiga Sekawan | Indonesia |
| Tin | CV United Smelting | Indonesia |
| Tin | CV Venus Inti Perkasa* | Indonesia |
| Tin | Dongguan CiEXPO Environmental Engineering Co., Ltd. | China |
| Tin | Dongguan City Xida Soldering Tin Products Co. | China |
| Tin | Dowa* | Japan |
| Tin | Dragon Silver Holdings Limited | China |
| Tin | DS Myanmar* | Myanmar |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | Vietnam |
| Tin | ENAF*12 | Bolivia |
| Tin | Estanho de Rondonia S.A.* | Brazil |
| Tin | Fabrica Auricchio Industria e Comercio Ltda.* | Brazil |
| Tin | Feinhutte Halsbrucke GmbH* | Germany |
| Tin | Fenix Metals* | Poland |
| Tin | Funsur Smelter | Peru |
| Tin | Gejiu City Fuxiang Industry and Trade Co., Ltd. | China |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | China |
| Tin | Gejiu Kai Meng Industry and Trade LLC | China |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd.* | China |
| Tin | Gejiu Yunxi Group Corp. | China |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | China |
| Tin | Gejiu Zi-Li | China |
| Tin | Global Advanced Metals Greenbushes Pty Ltd. | Australia |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd.* | China |
11 This smelter has the same identification number as the entity identified by RMI as “China Tin Group Co., Ltd.,” a conformant smelter.
12 This smelter has the same identification number as the entity identified by RMI as “EM Vinto,” a conformant smelter.
| Tin | GUANGXI HUA TIN GOLD MINUTE FEE, LTD. | China |
| Tin | Guangxi Nonferrous Metals Group | China |
| Tin | Guangxi Zhongshan Jin Yi Smelting Co., Ltd. | China |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | China |
| Tin | Hezhou Jinwei Tin Co., Ltd. | China |
| Tin | Hongqiao Metals (Kunshan) Co., Ltd. | China |
| Tin | HuiChang Hill Tin Industry Co., Ltd.* | China |
| Tin | Huichang Jinshunda Tin Co., Ltd. | China |
| Tin | Hulterworth Smelter | Malaysia |
| Tin | Ikuno Tin Smelter | Japan |
| Tin | Jiang Xi Jia Wang Technology Tin Products Environmental Ltd. | China |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | China |
| Tin | Jiangxi Nanshan*13 | China |
| Tin | Kundur Smelter | Indonesia |
| Tin | LIAN JING | China |
| Tin | Longnan Chuangyue Environmental Protection Technology Development Co., Ltd | China |
| Tin | Luna Smelter, Ltd.* | Rwanda |
| Tin | Ma An Shan Shu Guang Smelter Corp. | China |
| Tin | Ma'anshan Weitai Tin Co., Ltd. | China |
| Tin | Magnu's Minerais Metais e Ligas Ltda.* | Brazil |
| Tin | Malaysia Smelting Corporation Berhad (Port Klang) | Malaysia |
| Tin | Materials Eco-Refining Co., Ltd. | Japan |
| Tin | Melt Metais e Ligas S.A. | Brazil |
| Tin | Metahub Industries Sdn. Bhd. | Malaysia |
| Tin | Metallic Resources, Inc.* | United States of America |
| Tin | Minchali Metal Industry Co., Ltd. | Taiwan |
| Tin | Mineracao Taboca S.A.* | Brazil |
| Tin | Ming Li Jia smelt Metal Factory | China |
| Tin | Mining and processing tin-tungsten ore Giang Son - VQB Co., Ltd. | Vietnam |
| Tin | Mining Minerals Resources SARL* | Democratic Republic of The Congo |
| Tin | Ney Metals and Alloys | United States of America |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | Novosibirsk Processing Plant Ltd. | Russian Federation |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd.* | Thailand |
| Tin | O.M. Manufacturing Philippines, Inc.* | Philippines |
| Tin | OMODEO A. E S. METALLEGHE SRL | Italy |
13 This smelter has the same identification number as the entity identified by RMI as “Jiangxi New Nanshan Technology Ltd.,” a conformant smelter.
| Tin | OMSA | Bolivia |
| Tin | Pongpipat Company Limited | Myanmar |
| Tin | Precious Minerals and Smelting Limited | India |
| Tin | PT Artha Cipta Langgeng* | Indonesia |
| Tin | PT ATD Makmur Mandiri Jaya* | Indonesia |
| Tin | PT Babel Inti Perkasa* | Indonesia |
| Tin | PT Babel Surya Alam Lestari* | Indonesia |
| Tin | PT Bangka Prima Tin* | Indonesia |
| Tin | PT Bangka Serumpun* | Indonesia |
| Tin | PT Bangka Tin Industry | Indonesia |
| Tin | PT Belitung Industri Sejahtera* | Indonesia |
| Tin | PT Cipta Persada Mulia* | Indonesia |
| Tin | PT DS Jaya Abadi | Indonesia |
| Tin | PT Eunindo Usaha Mandiri | Indonesia |
| Tin | PT Inti Stania Prima | Indonesia |
| Tin | PT Karimun Mining | Indonesia |
| Tin | PT Kijang Jaya Mandiri | Indonesia |
| Tin | PT Lautan Harmonis Sejahtera | Indonesia |
| Tin | PT Masbro Alam Stania | Indonesia |
| Tin | PT Menara Cipta Mulia* | Indonesia |
| Tin | PT Mitra Graha Raya | Indonesia |
| Tin | PT Mitra Stania Prima* | Indonesia |
| Tin | PT Mitra Sukses Globalindo* | Indonesia |
| Tin | PT Panca Mega Persada | Indonesia |
| Tin | PT Prima Timah Utama* | Indonesia |
| Tin | PT Putera Sarana Shakti (PT PSS)* | Indonesia |
| Tin | PT Rajawali Rimba Perkasa* | Indonesia |
| Tin | PT Sariwiguna Binasentosa* | Indonesia |
| Tin | PT Stanindo Inti Perkasa* | Indonesia |
| Tin | PT Sukses Inti Makmur* | Indonesia |
| Tin | PT Sumber Jaya Indah | Indonesia |
| Tin | PT Timah Nusantara* | Indonesia |
| Tin | PT Timah Tbk Mentok* | Indonesia |
| Tin | PT Tinindo Inter Nusa* | Indonesia |
| Tin | PT Tirus Putra Mandiri | Indonesia |
| Tin | PT Tommy Utama* | Indonesia |
| Tin | Resind Industria e Comercio Ltda.* | Brazil |
| Tin | Rian Resources SDN. BHD.* | Malaysia |
| Tin | RIKAYAA GREENTECH PRIVATE LIMITED | India |
| Tin | Rui Da Hung* | Taiwan |
| Tin | Shenzhen Hong Chang Metal Manufacturing Factory | China |
| Tin | Sichuan Guanghan Jiangnan casting smelters | China |
| Tin | Sigma Tin Alloy Co., Ltd. | China |
| Tin | Soft Metais Ltda.* | Brazil |
| Tin | Solder Court Ltd. | China |
| Tin | Super Ligas* | Brazil |
| Tin | Suzhou Nuonengda Chemical Co., Ltd. | China |
| Tin | Taicang City Nancang Metal Material Co., Ltd. | China |
| Tin | Taiwan Huanliang | Taiwan |
| Tin | Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD. | Japan |
| Tin | Thai Nguyen Mining and Metallurgy Co., Ltd. | Vietnam |
| Tin | Thai Solder Industry Corp., Ltd.*14 | Thailand |
| Tin | Thailand Mine Factory | Thailand |
| Tin | Three green surface technology limited company | China |
| Tin | TIN PLATING GEJIU | China |
| Tin | Tin Technology & Refining* | United States of America |
| Tin | TONG LONG | China |
| Tin | Top-Team Technology (Shenzhen) Ltd. | China |
| Tin | TRATHO Metal Quimica* | Brazil |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | Vietnam |
| Tin | White Solder Metalurgia e Mineracao Ltda.* | Brazil |
| Tin | Woodcross Smelting Company Limited* | Uganda |
| Tin | WUJIANG CITY LUXE TIN FACTORY | China |
| Tin | Xiamen Honglu Tungsten Molybdenum Co., Ltd. | China |
| Tin | Xianghualing Tin Industry Co., Ltd. | China |
| Tin | XiHai - Liuzhou China Tin Group Co ltd | China |
| Tin | Xin Furukawa Metal ( Wuxi ) Co., Ltd. | China |
| Tin | XURI | China |
| Tin | Yifeng Tin | China |
| Tin | Yiquan Manufacturing | China |
| Tin | Yuecheng Tin Co., Ltd. | China |
| Tin | Yunnan Chengo Electric Smelting Plant | China |
| Tin | Yunnan Copper Zinc Industry Co., Ltd. | China |
| Tin | Yunnan Geiju Smelting Corp. | China |
| Tin | Yunnan Industrial Co., Ltd. | China |
| Tin | Yunnan Malipo Baiyi Kuangye Co. | China |
14 This smelter has the same identification number as the entity identified by RMI as “Thaisarco,” a conformant smelter.
| Tin | Yunnan Yunfan Non-ferrous Metals Co., Ltd.* | China |
| Tin | Zhongshan Jinye Smelting Co.,Ltd | China |
| Tungsten | A.L.M.T. Corp.* | Japan |
| Tungsten | ACL Metais Eireli | Brazil |
| Tungsten | Albasteel Industria e Comercio de Ligas Para Fundicao Ltd. | Brazil |
| Tungsten | Artek LLC | Russian Federation |
| Tungsten | Asia Tungsten Products Vietnam Ltd.* | Vietnam |
| Tungsten | ATI Tungsten Materials | United States of America |
| Tungsten | Avon Specialty Metals Ltd* | United Kingdom |
| Tungsten | Chaozhou Xianglu Tungsten Industry Co., Ltd. | China |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | China |
| Tungsten | China Molybdenum Co., Ltd.* | China |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd.* | China |
| Tungsten | CNMC (Guangxi) PGMA Co., Ltd. | China |
| Tungsten | Cronimet Brasil Ltda* | Brazil |
| Tungsten | DONGKUK INDUSTRIES CO., LTD. | Republic of Korea |
| Tungsten | Fujian Ganmin RareMetal Co., Ltd. | China |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | China |
| Tungsten | Fujian Xinlu Tungsten* | China |
| Tungsten | Ganzhou Beseem Ferrotungsten Co., Ltd. | China |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | China |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | China |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd.* | China |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd.* | China |
| Tungsten | Ganzhou Sunny Non-Ferrous Metals Co., Ltd.* | China |
| Tungsten | Ganzhou Yatai Tungsten Co., Ltd. | China |
| Tungsten | GEM Co., Ltd. | China |
| Tungsten | Global Tungsten & Powders LLC* | United States of America |
| Tungsten | H.C. Starck Tungsten GmbH* | Germany |
| Tungsten | HANNAE FOR T Co., Ltd. | Republic of Korea |
| Tungsten | Human Chun-Chang non-ferrous Smelting & Concentrating Co., Ltd. | China |
| Tungsten | Hunan Chenzhou Mining Co., Ltd.* | China |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | China |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | China |
| Tungsten | Hydrometallurg, JSC | Russian Federation |
| Tungsten | Japan New Metals Co., Ltd.* | Japan |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd.* | China |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | China |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd.* | China |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.* | China |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd.* | China |
| Tungsten | Jiangxi Xiushui Xianggan Nonferrous Metals Co., Ltd. | China |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd.* | China |
| Tungsten | JSC "Kirovgrad Hard Alloys Plant" | Russian Federation |
| Tungsten | Kenee Mining Corporation Vietnam | Vietnam |
| Tungsten | Kennametal Fallon* | United States of America |
| Tungsten | KGETS Co., Ltd. | Republic of Korea |
| Tungsten | Lianyou Metals Co., Ltd.* | Taiwan |
| Tungsten | Lianyou Resources Co., Ltd.* | Taiwan |
| Tungsten | LLC Volstok | Russian Federation |
| Tungsten | MALAMET SMELTING SDN. BHD. | Malaysia |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd.* | China |
| Tungsten | Masan High-Tech Materials* | Vietnam |
| Tungsten | Moliren Ltd. | Russian Federation |
| Tungsten | Nam Viet Cromit Joint Stock Company | Vietnam |
| Tungsten | Niagara Refining LLC* | United States of America |
| Tungsten | NPP Tyazhmetprom LLC | Russian Federation |
| Tungsten | OOO “Technolom” 1 | Russian Federation |
| Tungsten | OOO “Technolom” 2 | Russian Federation |
| Tungsten | Philippine Bonway Manufacturing Industrial Corporation | Philippines |
| Tungsten | Philippine Carreytech Metal Corp. | Philippines |
| Tungsten | Philippine Chuangxin Industrial Co., Inc.* | Philippines |
| Tungsten | Sanher Tungsten Vietnam Co., Ltd. | Vietnam |
| Tungsten | Shaoguan Xinhai Rendan Tungsten Industry Co. Ltd | China |
| Tungsten | Shinwon Tungsten (Fujian Shanghang) Co., Ltd.* | China |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | China |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | Vietnam |
| Tungsten | Tungsten Vietnam Joint Stock Company* | Vietnam |
| Tungsten | Unecha Refractory metals plant | Russian Federation |
| Tungsten | WBH*15 | Austria |
| Tungsten | Woltech Korea Co., Ltd. | Republic of Korea |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd.* | China |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | China |
| Tungsten | YUDU ANSHENG TUNGSTEN CO., LTD. | China |
| Tungsten | Zhangzhou Chuen Bao Apt Smeltery Co., Ltd. | China |
15 This smelter has the same identification number as the entity identified by RMI as “Wolfram Bergbau und Hutten AG,” a conformant smelter.