Keurig Dr Pepper Inc.
Conflict Minerals Report
For the reporting period from January 1, 2018 to December 31, 2018
Introduction
Keurig Dr Pepper, Inc. (the “Company” or “KDP”) is committed to sourcing products, components and materials from companies that share our values regarding respect for human rights, ethics and environmental responsibility. To that end, we are committed to the ethical sourcing of minerals including tin, tantalum, tungsten and gold. There is concern that 3TG, often referred to as “Conflict Minerals,” could originate from certain mines in the Democratic Republic of the Congo (“DRC”) which are controlled by armed militias who use the proceeds from the sale of these minerals to fund ongoing conflict in the region.
KDP has prepared this Conflict Minerals Report (this “Report”) pursuant to Rule 13p-1 (the “Rule”) under the Securities Exchange Act of 1934, as amended, for the reporting period from January 1, 2018 to December 31, 2018 (the “Reporting Period”).
This Report describes KDP’s due diligence process and compliance with the Rule’s requirements. The Rule requires disclosure of certain information when a reporting company manufactures, or contracts to manufacture, products which contain the minerals specified in the Rule, if those minerals are necessary to the functionality or production of such products. The specified minerals, which the Company collectively refers to in this Report as “3TG”, are gold, columbite-tantalite (coltan), cassiterite and wolframite and their derivatives, which are limited to tantalum, tin and tungsten. The “Covered Countries” for the purposes of the Rule and this Report are the Democratic Republic of the Congo, the Republic of the Congo, the Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia and Angola.
Background
On January 29, 2018, Dr Pepper Snapple Group, Inc. (“DPS”) entered into an Agreement and Plan of Merger (the “Merger Agreement”) by and among DPS, Maple Parent Holdings Corp. (“Maple”) and Salt Merger Sub, Inc. (“Merger Sub”), whereby Merger Sub merged with and into Maple, with Maple surviving the merger as a wholly owned subsidiary of DPS (the “Merger”). Maple is a holding company that conducts substantially all of its business through Keurig Green Mountain, Inc. (“Keurig”). Prior to the closing of the Merger, Keurig was a privately-held corporation, and DPS a publicly traded company. The Merger was consummated on July 9, 2018 (the “Merger Date”), at which time DPS changed its name to “Keurig Dr Pepper Inc.” and began trading on the New York Stock Exchange under the symbol “KDP”.
This Report covers the activities of the legacy-Keurig business during the Reporting Period, both from January 1, 2018 up to the Merger Date, as well as from the Merger Date through the end of the Reporting Period. There are no products that legacy-DPS business contracted to manufacture, or manufactured, during the Reporting Period which are considered in-scope products according to the Rule.
Reporting Scope
As described in this Report, certain 3TG are necessary to the functionality or production of products that the Company contracted to manufacture, or manufactured, during the Reporting Period. These products are Keurig’s brewers, as well as products manufactured and sold by the business formerly known as VKI Technologies Inc. (“VKI”) which is owned by Keurig Canada Inc., an indirect wholly-owned subsidiary of Keurig (collectively, Keurig’s and VKI’s in-scope products, the “Covered Products”).
Our Approach
KDP uses components and materials containing 3TG in its Covered Products but does not purchase 3TG directly from mines, smelters, or refiners. Therefore, we must collaborate with suppliers, industry peers, and other stakeholders as described in this Report.
KDP is a member of the Responsible Minerals Initiative (“RMI”), a multi-industry initiative addressing Conflict Minerals issues in the supply chain (unique member code KEUR). The RMI’s Conflict Minerals Reporting Template (“CMRT”) is a widely-used standard form to collect information through the supply chain, including the names of 3TG smelters and refiners (“SORs”). RMI also manages the Responsible Minerals Assurance Process (“RMAP”), which uses independent third-party audits to assess whether 3TG SORs have systems in place to source 3TG in conformance with the Organisation for Economic Co-operation and Development (“OECD”) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition (“OECD Guidance”)1. We use the CMRT to survey our suppliers and identify SORs in our supply chain, and the RMAP to determine the country of origin and conformance status of minerals.
In accordance with the Rule, KDP has in good faith conducted a reasonable country of origin inquiry (“RCOI”) regarding 3TG. This country of origin inquiry was designed to determine whether any of the 3TG used in the Covered Products originated in the Covered Countries and whether any of such 3TG may be from recycled or scrap sources. The Company also performed due diligence on the source and chain of custody of such 3TG as described in more detail below. KDP’s due diligence process is based on the OECD Guidance, referenced above.
Reasonable Country of Origin Inquiry
In 2018, KDP identified its direct suppliers of Covered Products, as well as one indirect supplier of Covered Products whom KDP engages with directly (such direct suppliers and indirect supplier, collectively, the “Suppliers”). KDP requested that each Supplier submit information to KDP using the CMRT.
The information submitted by KDP’s Suppliers in their CMRTs included information gathered by those Suppliers about the smelters and refiners identified in their own supply chains which KDP utilized to conduct further due diligence. As described in more detail below, KDP’s Responsible Sourcing team reviewed and analyzed each CMRT received.
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1 OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas Third Edition, 2016; https://www.oecd.org/daf/inv/mne/OECD-Due-Diligence-Guidance-Minerals-Edition3.pdf
KDP compared the list of SORs reported by Suppliers against the RMI’s Smelter Database2 to first determine which of the reported entities are known to be true smelters or refiners of 3TG (“Eligible SORs”). The list of Eligible SORs that our Suppliers reported as being in their supply chains is set forth in Annex I. The list of countries from which KDP believes the 3TG in its Covered Products may have originated is set forth in Annex II. This information was obtained through KDP’s membership in the RMI, using the RCOI report dated March 29, 2019 that is available to KDP as a member of RMI. Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP. Through our RCOI, we found that:
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| – | Some 3TG is sourced through SORs that are not yet RMAP-Conformant and therefore we have not yet determined the country of origin of those minerals; |
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| – | Some 3TG is sourced from RMAP-Conformant SORs, including SORs that source responsibly from the Covered Countries; and |
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| – | Some 3TG also may have originated from recycled or scrap sources. |
In addition to the RMI RCOI data available to KDP, select Suppliers reported to KDP that they source from the Covered Countries in their CMRTs:
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| – | Several Suppliers reported that they source from the Covered Countries and reported to KDP the names of the SORs found to source from the Covered Counties. KDP referenced the RMI Smelter Database and confirmed that the SOR names provided are RMAP Conformant. |
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| – | Two Suppliers provided SOR names that we confirmed have ceased operations or have been re-classified as non-smelters by the RMI. |
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| – | One Supplier reported that they source from the Covered Countries but did not provide the corresponding SOR names. In this case, KDP could not cross reference Smelter Database for SOR Conformance status. |
Ultimately, KDP relies on the RMI RCOI data as the most accurate information for our RCOI.
The information obtained from our Suppliers indicated that there was reason to believe that a portion of 3TG used in the Covered Products may have originated in the Covered Countries and were not exclusively from recycled or scrap sources, triggering the due diligence steps described in the following sections.
Due Diligence
Design of Due Diligence
KDP designed its due diligence measures in accordance with the OECD Guidance.
The OECD Guidance utilizes a five-step process for due diligence:
Step 1: Establish Strong Company Management Systems
Step 2: Identify and Assess Risks in the Supply Chain
Step 3: Design and Implement a Strategy to Respond to Identified Risks
Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices
Step 5: Report Annually on Supply Chain Due Diligence
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2 The RMI Smelter Database was exported and referenced as of our cutoff date of April 29, 2019:
http://www.responsiblemineralsinitiative.org/members/smelter-database/
Below is a description of KDP’s due diligence measures performed for the Reporting Period.
Due Diligence Measures Performed
Step 1: Establish Strong Company Management Systems:
Prior to the Merger Keurig adopted a policy which remains in effect relating to 3TG incorporating the standards set forth in the OECD Guidance (the “Conflict Minerals Policy”) in its Responsible Sourcing Supplier Guidelines. All of Keurig’s Suppliers are required to adhere to its Responsible Sourcing Supplier Guidelines, which are available on its website at www.KeurigGreenMountain.com/SupplierGuidelines. KDP is in the process of developing a company-wide Supplier Code of Conduct which will be in place by December 31, 2019 and will cover all of KDP’s Suppliers.
Keurig’s Conflict Minerals Policy states in part that Keurig is committed to: (1) supporting the aims and objectives of the U.S. legislation on the disclosure of 3TG; (2) not knowingly procuring 3TG that originates from facilities in the Covered Countries that are not considered conflict free; and (3) ensuring compliance with the Keurig Conflict Minerals Policy.
Members from the Company’s Procurement, Legal, and Sustainability Teams were involved in the due diligence process, which was led by the Company’s Responsible Sourcing Team. Members of our Executive Leadership Team were briefed on the Company’s due diligence procedures and results, and reviewed and approved this report.
Requirements related to Conflict Minerals and related due diligence activities are generally included in our material Keurig Supplier contracts.
KDP has established a system of controls and transparency to determine the SORs in its 3TG supply chain by creating a process to engage Suppliers. KDP uses a third party software platform to collect, store, analyze and aggregate Supplier data for reporting purposes. It is also used to send automated reminders to Suppliers throughout the due diligence process.
KDP provided Suppliers with links to the RMI e-learning academy and other resources. There were two new Suppliers included in our due diligence process this year. Both Suppliers completed a series of four supplier training modules through the RMI e-learning platform including the following topics: 1. Introduction to Conflict Minerals Due Diligence, 2. Supplier Survey, 3. Risk Assessment, and 4. Strong Management Systems. Throughout the due diligence process, KDP also engaged in ongoing communication and provided support to its Suppliers to facilitate the completion of their CMRTs.
Suppliers and employees are encouraged to report any ethical concerns or violations by any KDP employee or agent acting on behalf of the supplier or KDP. Concerns or violations may be reported in the following ways:
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| • | Call: 800-349-4248 (U.S. & Canada) or 001-888-243-8076 (Mexico). |
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| • | Mail: Attn: General Counsel | Keurig Dr Pepper | 5301 Legacy Drive | Plano, TX 75024. |
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| • | Web: www.integrity-helpline.com/kdp.jsp |
KDP retains Conflict Minerals documentation materials for five years after receipt.
Step 2: Identify and Assess Risks in the Supply Chain:
As described above, as part of its due diligence process KDP identified in scope Suppliers and requested that the Suppliers submit a completed CMRT.
Via our software platform, KDP then reviewed Suppliers’ completed CMRTs against a set of internally developed criteria for completeness and consistency. While 100% of Suppliers surveyed submitted a CMRT this year, there were several CMRTs that were incomplete, or where we identified inconsistencies which we were unable to resolve with the supplier before our cutoff date of April 29, 2019 despite numerous follow up requests. We intend to work with these suppliers to improve their responses year over year.
For Suppliers that indicated in their responses that they or a supplier in their supply chain did use 3TG in their part(s) and/or product(s) during the Reporting Period and provided the applicable smelter or refiner information, the Company reconciled the reported SORs against the RMI Smelter Database, which contains RMAP SOR Conformance status. (Available to RMI members at http://www.responsiblemineralsinitiative.org/members/smelter-database/)
Step 3: Design and Implement a Strategy to Respond to Identified Risks:
Where SORs were reported that are not RMAP-Conformant or Active (engaged in the RMAP program but not yet audited), KDP sent a notice via the platform asking applicable Suppliers to either work with their supply-chain to request the smelter to participate in the RMAP audit program, and/or work to transition away from the smelter, depending on level of identified risk. Further, there were also instances where inaccurate or outdated SOR information was reported to us, for example: smelters no longer in operation, or entities that could not be identified as known SORs. In these cases, we sent a notification to Suppliers asking them to work with their supply chain to obtain accurate smelter information. Our smelter action requests specified that we expect to see continuous improvement year over year in the reported smelter information.
In addition to the above, we also review our Suppliers’ CMRTs for due diligence activities, such as whether they have their own Conflict Minerals Policy. See below the Due Diligence Results section below where we report on the number of Suppliers who provided a policy that indicates a commitment to reasonably ensuring that only conflict-free materials and components are used in products/parts that are sold to KDP.
Lastly, several Suppliers indicated in their responses that they have not received complete information from their suppliers. When this happened, we requested that they work to improve their response rate.
Step 4: Carry Out Independent Third-Party Audit of Smelters’ and Refiners’ Due Diligence Practices
As a member of the RMI, KDP leverages information from the independent third party audits of the SORs facilitated by initiatives such as the RMI’s RMAP and the London Bullion Market Association (LBMA), or Responsible Jewelry Council (RJC).
Step 5: Report Annually on Supply Chain Due Diligence:
As discussed above, KDP is reporting on supply chain due diligence by publishing a Conflict Minerals Report for the Reporting Period on KDP’s corporate website (https://www.keurigdrpepper.com/en/our-company/ethics-and-compliance).
Due Diligence Results
Many of our Supplier responses represented their supply chain at a company level rather than being product specific. Therefore, the list of SORs contained in this report may contain more SORs than those that actually process the conflict minerals contained in our products.
The total number of unique entities reported as SORs by the KDP supply base as a result of the 2018 survey was 348. Of these:
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| – | 310 have been confirmed as being Eligible SORs by the RMI |
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| – | 32 were known to not be Eligible SORs, and |
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| – | 6 reported entities’ status could not be confirmed as of our cutoff date of April 29, 2019. This is compared to 52 entities in the prior year, a significant improvement. |
Of the 310 Eligible SORs reported by KDP Suppliers:
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| – | 251, or 81% had been validated by the RMI RMAP program as Conformant to an RMI recognized audit protocol (RMAP, LBMA, or RJC), a 1% increase from the prior year. |
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| – | 8 were in process or communication with RMAP, but had not achieved Conformant status as of April 26, 2019. |
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| – | The remaining 51 have not been validated by the RMAP program as Conformant. |
A list of all 310 of the Eligible SORs identified during the due diligence process is included in Annex I to this Report.
The 32 entities reported by our Suppliers that are not currently considered Eligible SORs fell into two categories:
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| – | 8 companies that had been reclassified by RMI due to better understanding of their business (group company or did not meet the definition of a smelter), and |
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| – | 24 Eligible SORs that had either temporarily or permanently suspended operations. |
As described above, we also requested Suppliers provide a policy that indicates a commitment to reasonably ensuring that only conflict free materials and components are used in products/parts sold to KDP. 40% of Suppliers provided a policy that meets this criterion, up from 37% in the prior year.
Future Due Diligence Improvements
KDP plans to continue to improve its due diligence measures by taking the following steps, among others:
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| – | Continuing to engage with Suppliers to obtain current, accurate and complete information about our supply chain; |
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| – | Continuing to encourage Suppliers to build up their own due diligence processes including their own conflict minerals policy; and |
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| – | Continuing to encourage Suppliers to request non-Conformant smelters to participate in the RMAP audit program, and/or work to transition away from such SORs. |
Determination
Based on the information obtained pursuant to the due diligence process described above, KDP believes that the SORs that may have been used to process the 3TG in KDP products include the SORs listed in Annex I below. The list of countries from which KDP believes the 3TG in their products may have originated as well as any materials from recycled and scrap sources, is set forth in Annex II. The SOR information collected from our Suppliers continued to include a number of SORs that had not been audited and determined to be RMAP Conformant by the RMI, or any other recognized organization. The possible existence of such SORs in our supply chain is sufficient to prevent us from declaring with certainty that no armed groups directly or indirectly benefited as a result of the mining, transport or processing of 3TG in our products.
KDP has provided information as of the date of this Report. Subsequent events, such as the inability or unwillingness of any suppliers, smelters or refiners to comply with Keurig’s Conflict Minerals Policy, may affect KDP’s future determinations.
Annex I
List of Smelters and Refiners
The table below represents a consolidated list of SORs (310 in total) identified by KDP’s Suppliers. The results are based on:
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| • | Information provided by KDP’s Suppliers in their CMRTs; and |
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| • | The Conformance status indicated in the RMI Smelter Database as of April 29, 2019 |
“SOR Country” refers to the location of the SOR, not the source of minerals. Refer to Annex II for the list of countries from which 3TG may have originated.
SORs that have been validated by the RMAP program as Conformant:
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| Metal | SOR Name | SOR Country | SOR ID |
| Gold | Advanced Chemical Company | UNITED STATES OF AMERICA | CID000015 |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN | CID000019 |
| Gold | Al Etihad Gold Refinery DMCC | UNITED ARAB EMIRATES | CID002560 |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY | CID000035 |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN | CID000041 |
| Gold | AngloGold Ashanti Corrego do Sitio Mineracao | BRAZIL | CID000058 |
| Gold | Argor-Heraeus S.A. | SWITZERLAND | CID000077 |
| Gold | Asahi Pretec Corp. | JAPAN | CID000082 |
| Gold | Asahi Refining Canada Ltd. | CANADA | CID000924 |
| Gold | Asahi Refining USA Inc. | UNITED STATES OF AMERICA | CID000920 |
| Gold | Asaka Riken Co., Ltd. | JAPAN | CID000090 |
| Gold | AU Traders and Refiners | SOUTH AFRICA | CID002850 |
| Gold | Aurubis AG | GERMANY | CID000113 |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES | CID000128 |
| Gold | Boliden AB | SWEDEN | CID000157 |
| Gold | C. Hafner GmbH + Co. KG | GERMANY | CID000176 |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA | CID000185 |
| Gold | Cendres + Metaux S.A. | SWITZERLAND | CID000189 |
| Gold | Chimet S.p.A. | ITALY | CID000233 |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF | CID000328 |
| Gold | DODUCO Contacts and Refining GmbH | GERMANY | CID000362 |
| Gold | Dowa | JAPAN | CID000401 |
| Gold | DS PRETECH Co., Ltd. | KOREA, REPUBLIC OF | CID003195 |
| Gold | DSC (Do Sung Corporation) | KOREA, REPUBLIC OF | CID000359 |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN | CID000425 |
| Gold | Emirates Gold DMCC | UNITED ARAB EMIRATES | CID002561 |
| Gold | Geib Refining Corporation | UNITED STATES OF AMERICA | CID002459 |
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| Gold | Gold Refinery of Zijin Mining Group Co., Ltd. | CHINA | CID002243 |
| Gold | HeeSung Metal Ltd. | KOREA, REPUBLIC OF | CID000689 |
| Gold | Heimerle + Meule GmbH | GERMANY | CID000694 |
| Gold | Heraeus Metals Hong Kong Ltd. | CHINA | CID000707 |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY | CID000711 |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd. | CHINA | CID000801 |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN | CID000807 |
| Gold | Istanbul Gold Refinery | TURKEY | CID000814 |
| Gold | Italpreziosi | ITALY | CID002765 |
| Gold | Japan Mint | JAPAN | CID000823 |
| Gold | Jiangxi Copper Co., Ltd. | CHINA | CID000855 |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION | CID000929 |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN | CID000937 |
| Gold | Kazzinc | KAZAKHSTAN | CID000957 |
| Gold | Kennecott Utah Copper LLC | UNITED STATES OF AMERICA | CID000969 |
| Gold | Kojima Chemicals Co., Ltd. | JAPAN | CID000981 |
| Gold | Korea Zinc Co., Ltd. | KOREA, REPUBLIC OF | CID002605 |
| Gold | Kyrgyzaltyn JSC | KYRGYZSTAN | CID001029 |
| Gold | L'Orfebre S.A. | ANDORRA | CID002762 |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF | CID001078 |
| Gold | Marsam Metals | BRAZIL | CID002606 |
| Gold | Materion | UNITED STATES OF AMERICA | CID001113 |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN | CID001119 |
| Gold | Metalor Technologies (Hong Kong) Ltd. | CHINA | CID001149 |
| Gold | Metalor Technologies (Singapore) Pte., Ltd. | SINGAPORE | CID001152 |
| Gold | Metalor Technologies (Suzhou) Ltd. | CHINA | CID001147 |
| Gold | Metalor Technologies S.A. | SWITZERLAND | CID001153 |
| Gold | Metalor USA Refining Corporation | UNITED STATES OF AMERICA | CID001157 |
| Gold | Metalurgica Met-Mex Penoles S.A. De C.V. | MEXICO | CID001161 |
| Gold | Mitsubishi Materials Corporation | JAPAN | CID001188 |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001193 |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA | CID002509 |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION | CID001204 |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.S. | TURKEY | CID001220 |
| Gold | Nihon Material Co., Ltd. | JAPAN | CID001259 |
| Gold | Ogussa Osterreichische Gold- und Silber-Scheideanstalt GmbH | AUSTRIA | CID002779 |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN | CID001325 |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION | CID001326 |
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| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION | CID000493 |
| Gold | PAMP S.A. | SWITZERLAND | CID001352 |
| Gold | Planta Recuperadora de Metales SpA | CHILE | CID002919 |
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION | CID001386 |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA | CID001397 |
| Gold | PX Precinox S.A. | SWITZERLAND | CID001498 |
| Gold | Rand Refinery (Pty) Ltd. | SOUTH AFRICA | CID001512 |
| Gold | REMONDIS PMR B.V. | NETHERLANDS | CID002582 |
| Gold | Royal Canadian Mint | CANADA | CID001534 |
| Gold | SAAMP | FRANCE | CID002761 |
| Gold | Safimet S.p.A | ITALY | CID002973 |
| Gold | SAXONIA Edelmetalle GmbH | GERMANY | CID002777 |
| Gold | SEMPSA Joyeria Plateria S.A. | SPAIN | CID001585 |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA | CID001622 |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA | CID001736 |
| Gold | Singway Technology Co., Ltd. | TAIWAN, PROVINCE OF CHINA | CID002516 |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION | CID001756 |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN, PROVINCE OF CHINA | CID001761 |
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN | CID001798 |
| Gold | SungEel HiMetal Co., Ltd. | KOREA, REPUBLIC OF | CID002918 |
| Gold | T.C.A S.p.A | ITALY | CID002580 |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN | CID001875 |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA | CID001916 |
| Gold | Tokuriki Honten Co., Ltd. | JAPAN | CID001938 |
| Gold | Torecom | KOREA, REPUBLIC OF | CID001955 |
| Gold | Umicore Brasil Ltda. | BRAZIL | CID001977 |
| Gold | Umicore Precious Metals Thailand | THAILAND | CID002314 |
| Gold | Umicore S.A. Business Unit Precious Metals Refining | BELGIUM | CID001980 |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES OF AMERICA | CID001993 |
| Gold | Valcambi S.A. | SWITZERLAND | CID002003 |
| Gold | Western Australian Mint (T/a The Perth Mint) | AUSTRALIA | CID002030 |
| Gold | WIELAND Edelmetalle GmbH | GERMANY | CID002778 |
| Gold | Yamakin Co., Ltd. | JAPAN | CID002100 |
| Gold | Yokohama Metal Co., Ltd. | JAPAN | CID002129 |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA | CID002224 |
| Tantalum | Asaka Riken Co., Ltd. | JAPAN | CID000092 |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA | CID000211 |
| Tantalum | D Block Metals, LLC | UNITED STATES OF AMERICA | CID002504 |
| Tantalum | Exotech Inc. | UNITED STATES OF AMERICA | CID000456 |
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| Tantalum | F&X Electro-Materials Ltd. | CHINA | CID000460 |
| Tantalum | FIR Metals & Resource Ltd. | CHINA | CID002505 |
| Tantalum | Global Advanced Metals Aizu | JAPAN | CID002558 |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES OF AMERICA | CID002557 |
| Tantalum | Guangdong Rising Rare Metals-EO Materials Ltd. | CHINA | CID000291 |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA | CID000616 |
| Tantalum | H.C. Starck Co., Ltd. | THAILAND | CID002544 |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY | CID002547 |
| Tantalum | H.C. Starck Inc. | UNITED STATES OF AMERICA | CID002548 |
| Tantalum | H.C. Starck Ltd. | JAPAN | CID002549 |
| Tantalum | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002550 |
| Tantalum | H.C. Starck Tantalum and Niobium GmbH | GERMANY | CID002545 |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA | CID002492 |
| Tantalum | Jiangxi Dinghai Tantalum & Niobium Co., Ltd. | CHINA | CID002512 |
| Tantalum | Jiangxi Tuohong New Raw Material | CHINA | CID002842 |
| Tantalum | Jiujiang Janny New Material Co., Ltd. | CHINA | CID003191 |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA | CID000914 |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA | CID000917 |
| Tantalum | Jiujiang Zhongao Tantalum & Niobium Co., Ltd. | CHINA | CID002506 |
| Tantalum | KEMET Blue Metals | MEXICO | CID002539 |
| Tantalum | KEMET Blue Powder | UNITED STATES OF AMERICA | CID002568 |
| Tantalum | LSM Brasil S.A. | BRAZIL | CID001076 |
| Tantalum | Metallurgical Products India Pvt., Ltd. | INDIA | CID001163 |
| Tantalum | Mineracao Taboca S.A. | BRAZIL | CID001175 |
| Tantalum | Mitsui Mining and Smelting Co., Ltd. | JAPAN | CID001192 |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA | CID001277 |
| Tantalum | NPM Silmet AS | ESTONIA | CID001200 |
| Tantalum | Power Resources Ltd. | MACEDONIA, THE FORMER YUGOSLAV REPUBLIC OF | CID002847 |
| Tantalum | QuantumClean | UNITED STATES OF AMERICA | CID001508 |
| Tantalum | Resind Industria e Comercio Ltda. | BRAZIL | CID002707 |
| Tantalum | Solikamsk Magnesium Works OAO | RUSSIAN FEDERATION | CID001769 |
| Tantalum | Taki Chemical Co., Ltd. | JAPAN | CID001869 |
| Tantalum | Telex Metals | UNITED STATES OF AMERICA | CID001891 |
| Tantalum | Ulba Metallurgical Plant JSC | KAZAKHSTAN | CID001969 |
| Tantalum | XinXing HaoRong Electronic Material Co., Ltd. | CHINA | CID002508 |
| Tantalum | Yanling Jincheng Tantalum & Niobium Co., Ltd. | CHINA | CID001522 |
| Tin | Alpha | UNITED STATES OF AMERICA | CID000292 |
|
| | | |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Co., Ltd. | CHINA | CID000228 |
| Tin | Chifeng Dajingzi Tin Industry Co., Ltd. | CHINA | CID003190 |
| Tin | China Tin Group Co., Ltd. | CHINA | CID001070 |
| Tin | CV Ayi Jaya | INDONESIA | CID002570 |
| Tin | CV Dua Sekawan | INDONESIA | CID002592 |
| Tin | CV Gita Pesona | INDONESIA | CID000306 |
| Tin | CV United Smelting | INDONESIA | CID000315 |
| Tin | CV Venus Inti Perkasa | INDONESIA | CID002455 |
| Tin | Dowa | JAPAN | CID000402 |
|
| | | |
| Tin | EM Vinto | BOLIVIA (PLURINATIONAL STATE OF) | CID000438 |
| Tin | Fenix Metals | POLAND | CID000468 |
| Tin | Gejiu Fengming Metallurgy Chemical Plant | CHINA | CID002848 |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA | CID000942 |
| Tin | Gejiu Non-Ferrous Metal Processing Co., Ltd. | CHINA | CID000538 |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Co., Ltd. | CHINA | CID001908 |
| Tin | Gejiu Zili Mining And Metallurgy Co., Ltd. | CHINA | CID000555 |
| Tin | Guangdong Hanhe Non-Ferrous Metal Co., Ltd. | CHINA | CID003116 |
| Tin | Guanyang Guida Nonferrous Metal Smelting Plant | CHINA | CID002849 |
| Tin | Huichang Jinshunda Tin Co., Ltd. | CHINA | CID000760 |
| Tin | Jiangxi New Nanshan Technology Ltd. | CHINA | CID001231 |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL | CID002468 |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA | CID001105 |
| Tin | Melt Metais e Ligas S.A. | BRAZIL | CID002500 |
| Tin | Metallic Resources, Inc. | UNITED STATES OF AMERICA | CID001142 |
| Tin | Metallo Belgium N.V. | BELGIUM | CID002773 |
| Tin | Metallo Spain S.L.U. | SPAIN | CID002774 |
| Tin | Mineracao Taboca S.A. | BRAZIL | CID001173 |
| Tin | Minsur | PERU | CID001182 |
| Tin | Mitsubishi Materials Corporation | JAPAN | CID001191 |
| Tin | Modeltech Sdn Bhd | MALAYSIA | CID002858 |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND | CID001314 |
| Tin | O.M. Manufacturing Philippines, Inc. | PHILIPPINES | CID002517 |
| Tin | Operaciones Metalurgicas S.A. | BOLIVIA (PLURINATIONAL STATE OF) | CID001337 |
| Tin | PT Aries Kencana Sejahtera | INDONESIA | CID000309 |
| Tin | PT Artha Cipta Langgeng | INDONESIA | CID001399 |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA | CID002503 |
| Tin | PT Babel Inti Perkasa | INDONESIA | CID001402 |
| Tin | PT Babel Surya Alam Lestari | INDONESIA | CID001406 |
| Tin | PT Bangka Prima Tin | INDONESIA | CID002776 |
| Tin | PT Bangka Serumpun | INDONESIA | CID003205 |
| Tin | PT Bangka Tin Industry | INDONESIA | CID001419 |
| Tin | PT Belitung Industri Sejahtera | INDONESIA | CID001421 |
| Tin | PT Bukit Timah | INDONESIA | CID001428 |
| Tin | PT DS Jaya Abadi | INDONESIA | CID001434 |
| Tin | PT Inti Stania Prima | INDONESIA | CID002530 |
| Tin | PT Karimun Mining | INDONESIA | CID001448 |
| Tin | PT Kijang Jaya Mandiri | INDONESIA | CID002829 |
|
| | | |
| Tin | PT Menara Cipta Mulia | INDONESIA | CID002835 |
| Tin | PT Mitra Stania Prima | INDONESIA | CID001453 |
| Tin | PT Panca Mega Persada | INDONESIA | CID001457 |
| Tin | PT Premium Tin Indonesia | INDONESIA | CID000313 |
| Tin | PT Prima Timah Utama | INDONESIA | CID001458 |
| Tin | PT Rajehan Ariq | INDONESIA | CID002593 |
| Tin | PT Refined Bangka Tin | INDONESIA | CID001460 |
| Tin | PT Sariwiguna Binasentosa | INDONESIA | CID001463 |
| Tin | PT Stanindo Inti Perkasa | INDONESIA | CID001468 |
| Tin | PT Sukses Inti Makmur | INDONESIA | CID002816 |
| Tin | PT Sumber Jaya Indah | INDONESIA | CID001471 |
| Tin | PT Timah Tbk Kundur | INDONESIA | CID001477 |
| Tin | PT Timah Tbk Mentok | INDONESIA | CID001482 |
| Tin | PT Tinindo Inter Nusa | INDONESIA | CID001490 |
| Tin | PT Tommy Utama | INDONESIA | CID001493 |
| Tin | Resind Industria e Comercio Ltda. | BRAZIL | CID002706 |
| Tin | Rui Da Hung | TAIWAN, PROVINCE OF CHINA | CID001539 |
| Tin | Soft Metais Ltda. | BRAZIL | CID001758 |
| Tin | Thaisarco | THAILAND | CID001898 |
| Tin | Tin Technology & Refining | UNITED STATES OF AMERICA | CID003325 |
| Tin | White Solder Metalurgia e Mineracao Ltda. | BRAZIL | CID002036 |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA | CID002158 |
| Tin | Yunnan Tin Company Limited | CHINA | CID002180 |
| Tungsten | A.L.M.T. Corp. | JAPAN | CID000004 |
| Tungsten | ACL Metais Eireli | BRAZIL | CID002833 |
| Tungsten | Asia Tungsten Products Vietnam Ltd. | VIET NAM | CID002502 |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA | CID002513 |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA | CID000258 |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA | CID000499 |
| Tungsten | Ganzhou Haichuang Tungsten Co., Ltd. | CHINA | CID002645 |
|
| | | |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA | CID000875 |
| Tungsten | Ganzhou Jiangwu Ferrotungsten Co., Ltd. | CHINA | CID002315 |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA | CID002494 |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES OF AMERICA | CID000568 |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA | CID000218 |
| Tungsten | H.C. Starck Smelting GmbH & Co. KG | GERMANY | CID002542 |
| Tungsten | H.C. Starck Tungsten GmbH | GERMANY | CID002541 |
| Tungsten | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000766 |
| Tungsten | Hunan Chuangda Vanadium Tungsten Co., Ltd. Wuji | CHINA | CID002579 |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA | CID000769 |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION | CID002649 |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN | CID000825 |
| Tungsten | Jiangwu H.C. Starck Tungsten Products Co., Ltd. | CHINA | CID002551 |
| Tungsten | Jiangxi Gan Bei Tungsten Co., Ltd. | CHINA | CID002321 |
| Tungsten | Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd. | CHINA | CID002318 |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA | CID002317 |
| Tungsten | Jiangxi Yaosheng Tungsten Co., Ltd. | CHINA | CID002316 |
| Tungsten | Kennametal Fallon | UNITED STATES OF AMERICA | CID000966 |
| Tungsten | Kennametal Huntsville | UNITED STATES OF AMERICA | CID000105 |
| Tungsten | Malipo Haiyu Tungsten Co., Ltd. | CHINA | CID002319 |
| Tungsten | Masan Tungsten Chemical LLC (MTC) | VIET NAM | CID002543 |
| Tungsten | Moliren Ltd. | RUSSIAN FEDERATION | CID002845 |
| Tungsten | Niagara Refining LLC | UNITED STATES OF AMERICA | CID002589 |
| Tungsten | Philippine Chuangxin Industrial Co., Inc. | PHILIPPINES | CID002827 |
| Tungsten | South-East Nonferrous Metal Company Limited of Hengyang City | CHINA | CID002815 |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM | CID001889 |
| Tungsten | Unecha Refractory metals plant | RUSSIAN FEDERATION | CID002724 |
| Tungsten | Wolfram Bergbau und Hutten AG | AUSTRIA | CID002044 |
| Tungsten | Woltech Korea Co., Ltd. | KOREA, REPUBLIC OF | CID002843 |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA | CID002320 |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA | CID002082 |
| Tungsten | Xinfeng Huarui Tungsten & Molybdenum New Material Co., Ltd. | CHINA | CID002830 |
| Tungsten | Xinhai Rendan Shaoguan Tungsten Co., Ltd. | CHINA | CID002095 |
SORs that have not been validated by the RMAP program as Conformant:
|
| | | |
| Metal | SOR Name | SOR Country | SOR ID |
| Gold | Abington Reldan Metals, LLC | UNITED STATES OF AMERICA | CID002708 |
| Gold | African Gold Refinery | UGANDA | CID003185 |
| Gold | Atasay Kuyumculuk Sanayi Ve Ticaret A.S. | TURKEY | CID000103 |
| Gold | Bangalore Refinery | INDIA | CID002863 |
| Gold | Caridad | MEXICO | CID000180 |
| Gold | Chugai Mining | JAPAN | CID000264 |
| Gold | Daye Non-Ferrous Metals Mining Ltd. | CHINA | CID000343 |
| Gold | Degussa Sonne / Mond Goldhandel GmbH | GERMANY | CID002867 |
| Gold | Fidelity Printers and Refiners Ltd. | ZIMBABWE | CID002515 |
| Gold | GCC Gujrat Gold Centre Pvt. Ltd. | INDIA | CID002852 |
| Gold | Great Wall Precious Metals Co., Ltd. of CBPM | CHINA | CID001909 |
| Gold | Guangdong Jinding Gold Limited | CHINA | CID002312 |
| Gold | Guoda Safina High-Tech Environmental Refinery Co., Ltd. | CHINA | CID000651 |
| Gold | Hangzhou Fuchunjiang Smelting Co., Ltd. | CHINA | CID000671 |
| Gold | Hunan Chenzhou Mining Co., Ltd. | CHINA | CID000767 |
| Gold | Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd. | CHINA | CID000773 |
| Gold | HwaSeong CJ CO., LTD. | KOREA, REPUBLIC OF | CID000778 |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION | CID000927 |
| Gold | Kaloti Precious Metals | UNITED ARAB EMIRATES | CID002563 |
| Gold | Kazakhmys Smelting LLC | KAZAKHSTAN | CID000956 |
| Gold | KGHM Polska Miedz Spolka Akcyjna | POLAND | CID002511 |
| Gold | Kyshtym Copper-Electrolytic Plant ZAO | RUSSIAN FEDERATION | CID002865 |
| Gold | L'azurde Company For Jewelry | SAUDI ARABIA | CID001032 |
| Gold | Lingbao Gold Co., Ltd. | CHINA | CID001056 |
| Gold | Lingbao Jinyuan Tonghui Refinery Co., Ltd. | CHINA | CID001058 |
| Gold | Luoyang Zijin Yinhui Gold Refinery Co., Ltd. | CHINA | CID001093 |
| Gold | Modeltech Sdn Bhd | MALAYSIA | CID002857 |
| Gold | Morris and Watson | NEW ZEALAND | CID002282 |
| Gold | Morris and Watson Gold Coast | AUSTRALIA | CID002866 |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN | CID001236 |
| Gold | NH Recytech Company | KOREA, REPUBLIC OF | CID003189 |
| Gold | Pease & Curren | UNITED STATES OF AMERICA | CID002872 |
| Gold | Penglai Penggang Gold Industry Co., Ltd. | CHINA | CID001362 |
| Gold | QG Refining, LLC | UNITED STATES OF AMERICA | CID003324 |
|
| | | |
| Gold | Refinery of Seemine Gold Co., Ltd. | CHINA | CID000522 |
| Gold | Sabin Metal Corp. | UNITED STATES OF AMERICA | CID001546 |
| Gold | SAFINA A.S. | CZECHIA | CID002290 |
| Gold | Sai Refinery | INDIA | CID002853 |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF | CID001555 |
| Gold | Samwon Metals Corp. | KOREA, REPUBLIC OF | CID001562 |
| Gold | Shandong Tiancheng Biological Gold Industrial Co., Ltd. | CHINA | CID001619 |
| Gold | State Research Institute Center for Physical Sciences and Technology | LITHUANIA | CID003153 |
| Gold | Sudan Gold Refinery | SUDAN | CID002567 |
| Gold | Tongling Nonferrous Metals Group Co., Ltd. | CHINA | CID001947 |
| Gold | Tony Goetz NV | BELGIUM | CID002587 |
| Gold | TOO Tau-Ken-Altyn | KAZAKHSTAN | CID002615 |
| Gold | Universal Precious Metals Refining Zambia | ZAMBIA | CID002854 |
| Gold | Yunnan Copper Industry Co., Ltd. | CHINA | CID000197 |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM | CID002703 |
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy JSC | VIET NAM | CID002572 |
| Tin | Estanho de Rondonia S.A. | BRAZIL | CID000448 |
| Tin | HuiChang Hill Tin Industry Co., Ltd. | CHINA | CID002844 |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002573 |
| Tin | Pongpipat Company Limited | MYANMAR | CID003208 |
| Tin | Super Ligas | BRAZIL | CID002756 |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM | CID002574 |
| Tungsten | Hunan Litian Tungsten Industry Co., Ltd. | CHINA | CID003182 |
| Tungsten | Jiangxi Dayu Longxintai Tungsten Co., Ltd. | CHINA | CID002647 |
| Tungsten | Jiangxi Minmetals Gao'an Non-ferrous Metals Co., Ltd. | CHINA | CID002313 |
Annex II
Countries from which the minerals in the Covered Products may have originated
Based on RMI’s Reasonable Country of Origin Inquiry report dated March 29, 2019, the countries of origin of the 3TG processed by SORs listed in ANNEX I are believed to include the following Note that the RMI RCOI report only includes information for SORs that are “Conformant” according to RMAP:
Gold:
|
| | | | |
| Argentina | | Finland | | Niger |
| Armenia | | Georgia | | Papua New Guinea |
| Australia | | Ghana | | Peru |
| Azerbaijan | | Guatemala | | Philippines |
| Benin | | Guinea | | Puerto Rico |
| Bolivia (Plurinational-State of) | | Guyana | | Russian Federation |
| Brazil | | Honduras | | Saudi Arabia |
| Burkina Faso | | Indonesia | | Senegal |
| Canada | | Iran | | Slovakia |
| Chile | | Ivory Coast | | Solomon Islands |
| China | | Kazakhstan | | South Africa |
| Colombia | | Kenya | | Spain |
| Congo, Democratic Republic of the | | Kyrgyzstan | | Suriname |
| Cyprus | | Laos | | Swaziland |
| Dominican Republic | | Lebanon | | Sweden |
| Ecuador | | Malaysia | | Tanzania |
| Egypt | | Mali | | Thailand |
| Eritrea | | Mauritania | | Togo |
| Ethiopia | | Mauritius | | Turkey |
| | | Mexico | | United States of America |
| | | Mongolia | | Uruguay |
| | | Morocco | | Uzbekistan |
| | | Namibia | | Zambia |
| | | Nicaragua | | |
Tantalum:
|
| | | | |
| Australia | | Colombia | | Malaysia |
| Austria | | Congo, Democratic-Republic of the | | Mozambique |
| Bolivia (Plurinational-State of) | | Ethiopia | | Nigeria |
| Brazil | | Guinea | | Russian Federation |
| Burundi | | India | | Rwanda |
| China | | Madagascar | | Sierra Leone |
| | | | | Thailand |
Tin:
|
| | | | |
| Australia | | Guinea | | Russian Federation |
| Bolivia (Plurinational-State of) | | Indonesia | | Rwanda |
| Brazil | | Laos | | Taiwan |
| Burundi | | Malaysia | | Thailand |
| China | | Mongolia | | Uganda |
| Congo, Democratic-Republic of the | | Myanmar | | United Kingdom of Great-Britain and Northern Ireland |
| | | Nigeria | | Venezuela |
| | | Peru | | |
| | | Portugal | | |
Tungsten:
|
| | |
| Australia | | Mongolia |
| Bolivia (Plurinational-State of) | | Myanmar |
| Brazil | | Nigeria |
| Burundi | | Peru |
| China | | Russian Federation |
| Congo, Democratic-Republic of the | | Rwanda |
| Guinea | | Taiwan |
| Indonesia | | Thailand |
| Laos | | United Kingdom of Great-Britain and Northern Ireland |
| Malaysia | | United States of America |
