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TAT Technologies Ltd. — Environmental & Social Information 2016
May 31, 2016
7072_rns_2016-05-31_312a6fee-1210-4ab7-ba54-92bc5299a26c.pdf
Environmental & Social Information
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UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
Form SD
SPECIALIZED DISCLOSURE REPORT
TAT TECHNOLOGIES LTD.
(Exact Name of Registrant as Specified in Charter)
Commission file number: 0-16050
TAT TECHNOLOGIES LTD.
(Exact name of Registrant as specified in its charter and translation of Registrant's name into English)
Israel
(Jurisdiction of incorporation or organization)
P.O. Box 80, Gedera 70750, Israel
(Address of principal executive offices)
Check the appropriate box to indicate the rule pursuant to which this form is being filed, and provide the period to which the information in this form applies:
☒Rule 13p-1 under the Securities Exchange Act (17 CFR 240.13p-1) for the reporting period from January 1 to December 31, 2015.
Section 1 - Conflict Minerals Disclosure
TAT Technologies Ltd. (the "Company") evaluated its current product lines and determined that certain products it manufactures or contracts to manufacture contain tin and/or gold (3TG), which are necessary to the functionality or production of its products.
Based on a reasonable country of origin inquiry ("RCOI") performed, the Company cannot yet determine whether the conflict minerals used in its products originated or may have originated in the Democratic Republic of the Congo or an adjoining country.
As a result we have filed a Conflict Minerals Report.
A copy of The Company's Conflict Minerals Report is provided as Exhibit 1.01 hereto and is publicly available at: www.TAT-Technologies.com under "Investor Relations" in "Press Releases". The content of any website referred to in this Form SD is included for general information only and is not incorporated by reference in this Form SD.
Section 2 - Exhibits
Exhibit 1.01 - Conflict Minerals Report as required by Items 1.01 and 1.02 of this Form.
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 undersigned, thereunto duly authorized.
TAT TECHNOLOGIES LTD. (Registrant)
By: /s/ Guy Nathanzon Guy Nathanzon Chief Financial Officer
Date: May 31, 2016
Exhibit 1.01
TAT Technologies Ltd. Conflict Minerals Report For The Year Ended December 31, 2015
This report for the year ended December 31, 2015 is presented to comply with Rule 13p-1 under the Securities Exchange Act of 1934 (the Rule). For the purpose of the required Reasonable Country of Origin Inquiry (RCOI), TAT Technologies Ltd. continued to receive supply chain responses through May 31, 2016. The Rule was adopted by the Securities and Exchange Commission (SEC) to implement reporting and disclosure requirements related to Conflict Minerals as directed by the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act). The Rule imposes certain reporting obligations on SEC registrants whose manufactured products contain Conflict Minerals which are necessary to the functionality or production of their products. Conflict Minerals are defined as tin, tantalum, tungsten, and gold (3TG) for the purposes of this assessment. These requirements apply to registrants whatever the geographic origin of the Conflict Minerals and whether or not they fund armed conflict.
If a registrant can establish that the Conflict Minerals originated from sources other than the Democratic Republic of the Congo or an adjoining country (the Covered Countries), or from recycled and scrap sources, they must submit a Form SD which describes the Reasonable Country of Origin Inquiry completed.
If a registrant has reason to believe that any of the Conflict Minerals in their supply chain may have originated in the Covered Countries, or if they are unable to determine the country of origin of those Conflict Minerals, then the issuer must exercise due diligence on the Conflict Minerals' source and chain of custody. The registrant must annually submit a report, Conflict Minerals Report (CMR), to the SEC that includes a description of those due diligence measures.
1. Company Overview
This report has been prepared by the management of TAT Technologies Ltd. (herein referred to as "TAT" the "Company," "we," "us," or "our"). The information includes the activities of all relevant subsidiaries that are required to be consolidated.
TAT Technologies Ltd. is a leading provider of services and products to the commercial and military aerospace and ground defense industries. TAT operates under four segments: (i) Original Equipment Manufacturing or "OEM" of Heat Management Solutions (ii) Heat Transfer Services and Products (iii) Maintenance, Repair and Overhaul or "MRO" services of Aviation Components; and (iv) Overhaul and coating of jet engine components.
TAT's activities in the area of OEM Heat Management Solutions are focused on the design, development, manufacture, and sale of the following: (i) a broad range of heat transfer components including heat exchangers, pre-coolers and oil/fuel hydraulic coolers used in mechanical and electronic systems on-board commercial, military and business aircraft; (ii) environmental control and cooling systems on board aircraft and for ground applications; and (iii) a variety of other electronic and mechanical aircraft accessories and systems such as pumps, valves, power systems and turbines.
TAT's activities in the area of Heat Transfer Services and Products include the maintenance, repair and overhaul of heat transfer equipment and to a lesser extent, the manufacture of certain heat transfer product parts. TAT's Limco subsidiary operates an FAA certified repair station, which provides heat transfer MRO services and products for airlines, air cargo carriers, maintenance service centers and the military.
TAT's activities in the area of MRO services for Aviation Components include the maintenance, repair and overhaul of APUs, Landing Gears and other aircraft components. TAT's Piedmont subsidiary operates an FAA certified repair station, which provides aircraft component MRO services for airlines, air cargo carriers, maintenance service centers and the military.
TAT's activities in the area of jet engine overhaul includes the overhaul and coating of jet engine components such as turbine vanes and blades, fan blades, variable inlet guide vanes, afterburner flaps and other components.
2. Products Overview
TAT is principally engaged in the following activities:
- · Design, development, manufacture and sale of a broad range of heat transfer equipment and solutions;
- · Remanufacture, overhaul and repair of heat transfer equipment;
- · Maintenance, repair and overhaul of auxiliary power units, landing gears and related components;
- · Design, development and manufacture of aviation and flow control accessories including fuel components, secondary power systems, and various instrumentation and electronic assemblies; and
- · Design, development and manufacture of environmental control and cooling systems.
- · Overhaul and coating of jet engine components
The products developed, repaired, and maintained by TAT are primarily used for airborne systems on commercial and military aircrafts as well as for defense ground systems. The principal markets of TAT are in Israel, Europe and the United States.
Based upon TAT's internal assessment that included review of all company products in order to identify the products that may include the relevant minerals, the Company uses Conflict Minerals (Gold and Tin) through its OEM manufacturing processes, and as such may be included in Heat Exchangers Cores and Air Conditioners manufactured by us.
3. Reasonable Country of Origin Inquiry (RCOI)
Based on our products analysis, TAT has concluded in good faith that during the calendar year 2015, out of the above SEC defined "Conflict Minerals", Gold and tin can be found in our products. Therefore, the products that we manufacture are subject to the reporting obligations of Rule 13p-1. The applicable suppliers list which TAT purchased from during the calendar year 2015 was issued using TAT's IT systems by the purchasing department manager. The list includes a total of 721 suppliers which was segmented according to the type of material or component the supplier provides such as: papers, rubber, plastic, metal, electronics, etc. All of the suppliers' categories were excluded (a total of 712 suppliers) except for the electronics category, since these suppliers provided other components than "Electronics", which did not contain Conflict Minerals. TAT's finalized level 1 suppliers list includes 9 suppliers of which one of them did not cooperate. Therefore as part of our risk based approach, we included his 10 relevant suppliers as part of our relevant suppliers list. The cumulative number of approached suppliers was 18.
The methods we used in order to determine the origin of Conflict Minerals in our products included:
- · Sending letters to our direct suppliers, explaining the rule and referring the suppliers to online training materials and instructions;
- · Soliciting survey responses from relevant suppliers of components of our products, using the most updated version of the standard Conflict Minerals Reporting Template (CMRT) designed by the CFSI;
- · Reviewing responses that we received from our suppliers and following up on inconsistent, incomplete, and inaccurate responses; and
- · Sending reminders to suppliers who did not respond to our requests for information.
Our supply chain is complex. There are multiple tiers between our company and the relevant smelters and refineries. Accordingly, we rely on our direct suppliers to provide information on the origin of the Conflict Minerals contained in components which are included in our products. Using our supply chain due diligence processes, driving accountability within the supply chain by leveraging the industry standard CFSI/CFS program, and continuing our outreach efforts we hope to further develop transparency into our supply chain.
Despite having conducted a good faith reasonable country of origin inquiry, we have been unable to determine the origin of all of the 3TG used in our products. Therefore we have performed the due diligence activities and detailed these efforts in this Conflict Minerals Report.

4. Design of Due Diligence
Our due diligence processes and efforts have been developed in conjunction with the 2nd edition of The Organization for Economic Co-operation and Development (OECD) Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas (OECD Guidance) and the related supplements for gold and for tin, tantalum and tungsten. The Company designed its due diligence process, management and measures to conform in all material respects with the framework OECD Guidance
5. Due Diligence Performed
The due diligence measures we performed are presented below according to the five-step framework established by the OECD:
Step 1. Establish Strong Company Management Systems
Conflict Minerals Policy
We have reviewed our Conflict Minerals Policy in order to assess whether any updates were required. As mentioned in our policy, TAT strives to only use 3TG minerals from smelters that have been audited and verified as conflict free by the Conflict Free Smelter Program ("CFSP") or equivalent programs as they become available. Our policy with respect to the sourcing of Conflict Minerals can be found at http://www.tat-technologies.com/Corporate-Governance-Documents.html .
Internal Team
The Company established a management system for complying with the applicable rules. Our management system includes the development of a Conflict Minerals Task Force led by our Chief Financial Officer and a team of subject matter personnel from relevant functions in the Company such as, purchasing, quality assurance and manufacturing. Senior management is briefed about the results of our due diligence efforts on a regular basis. We are periodically reporting to the Audit Committee with respect to our due diligence process and compliance obligations.
Supplier Engagement
As part of our efforts to strengthen engagement with suppliers, we direct and provide our suppliers with training and electronic instruction related to Conflict Minerals, including the CMRT, our Conflict Minerals policy, and FAQs from the U.S. Securities and Exchange Commission. In addition, suppliers that handle 3TG are expected to have their own programs for implementing their own policies.
Procurement processes
TAT has updated its standard Terms and Conditions with suitable Conflict Minerals contractual language which requires our suppliers to comply with the rule's reporting requirements.
Maintain records
TAT has established a due diligence compliance process and set forth documentation and record maintenance mechanism to ensure the retaining of relevant documentation in a structured electronic database.
Grievance Mechanism
TAT has established a grievance mechanism which is published on our policy. Whereby concerns and violations of the Conflict Minerals Policy can be reported to its non-executive members or its subcommittees through our official grievance channels (at: [email protected]).

Step 2. Identify and Assess Risks in the Supply Chain
In order to identify risks in our supply chain we assessed two primary risks:
-
- The risk of not receiving on time and accurate information from the supplier; and
-
- The risk of not being able to replace a supplier while trying to move towards the goal of being a conflict free company.
We have segmented our suppliers into three risk levels (high, medium and low) by referring to Conflict Minerals-related risks based on suppliers characteristics, such as: the geographical location of the supplier or manufacturer, whether or not the supplier is a SEC registrant, volume of spending during 2015 and the extent to which the company is dependent upon any particular supplier or, conversely, the availability of alternative suppliers. This segmentation allowed us to invest our risk mitigation efforts according to the supplier level of risk.
As part of the risk assessment phase, we have identified that out of the responses received, 78.6% of TAT's level 1 suppliers and manufacturers list have policy in place which addresses the Conflict Minerals sourcing in the products provided to TAT.
We relied on these supplier's responses to provide us with information about the source of Conflict Minerals contained in the components supplied to us. Our direct suppliers are similarly reliant upon information provided by their suppliers.
We have identified, to the best of our efforts, the smelters/refiners in the supply chain by conducting a supply chain survey using the CMRT in order to facilitate disclosure and communication of information regarding smelters that provide materials to our supply chain. In addition, TAT compared smelters and refiners identified by the supply chain survey against the list of facilities that have received a "Conflict Free" designation from the CFSP.
Step 3. Design and Implement a Strategy to Respond to Identified Risks
TAT continues to work with suppliers who are sourcing from non-conflict free smelters to move towards using Conflict Free smelters within a reasonable time frame. The time frame depends on the supplier's level of risk as mentioned above. Our management strategy includes: Follow-up processes (including e-mail communication and manual outreach) to escalate any identified issues associated with non-responsive or problematic responses.
The supply chain Due Diligence is a dynamic process which requires on-going risk monitoring. In order to ensure effective management of risks, we review the risk identification process occasionally and update the risk mitigation strategy accordingly.
Step 4. Carry Out Independent Third-Party Audit of Smelter/Refiner's Due Diligence Practices
The Company does not have a direct relationship with 3TG smelters and refiners, nor do we perform direct audits of these entities that provide our supply chain the 3TG. However, we do rely upon the industry (for example, CFSI) efforts to influence smelters and refineries to get audited and certified through CFSI's CFS program.
Step 5. Report Annually on Supply Chain Due Diligence
In addition to this report, for further information about our supply chain Conflict Minerals policy, including our approach for supply chain due diligence and supplier expectation, please see it at: http://www.tat-technologies.com/Press-Releases.html.
6. Results of Assessment
We conducted a supply-chain survey of the 18 suppliers we identified as potential providers of necessary Conflict Minerals to our products.
The overall response rate to this survey was approximately 78% containing the names and locations of smelters and refiners (see Annex 1) and country of origin see (Annex 2) which process Conflict Minerals. Of this response rate 1 supplier reported that his products do not contain Conflict Minerals and 3 suppliers reported that they are conflict free (both from DRC and not from DRC).
By adopting a methodology based on the OECD guidelines and the CFSI template, TAT concludes that the information gathered from the smelters and refiners in its supply chain represents the most reasonable known mine of origin information available as the OECD Due Diligence Guidance is currently the best known efforts to obtain mine and country of origin information.
TAT has encountered difficulty in identifying entities downstream from TAT's products. Therefore, TAT relies on its direct suppliers to provide information about the source of Conflict Minerals contained in the components supplied to TAT.
In addition, nformation gathered from TAT's suppliers is not on a continuous, real-time basis. Therefore, TAT can only provide reasonable, not absolute, assurance regarding the source and chain of custody of the necessary Conflict Minerals, since the information comes from direct and secondary suppliers and independent third party audit programs
7. Continuous improvement efforts to mitigate risk
As we move towards developing our due diligence program, we intend to take the following steps to continue to mitigate any possible risk that the necessary Conflict Minerals in our products could benefit armed groups in the DRC or adjoining countries:
- · Enhance supplier communication to improve due diligence data accuracy and completion.
- · Continue to influence additional suppliers to obtain CFS status through our supply chain, where possible.
- · Continue to implement risk mitigation actions such as intensive follow up on high risk non responsive or non-compliant suppliers.
Smelters and refiners verified as conflict free or in the audit process:
| Tin | 69 of 91 (76%) |
|---|---|
| Tantalum | 38 of 42 (90%) |
| Tungsten | 25 of 28 (89%) |
| Gold | 88 of 117 (75%) |
| Total | 220 of 278 (79%) |
5
Status of identified smelters and refiners:
| 2015 | |
|---|---|
| Verified Conflict Free | 191 |
| Participating in an audit process | 26 |
| Total | 217 |
Safe Harbor for Forward-Looking Statements
This press release contains forward-looking statements which include, without limitation, statements regarding possible or assumed future operation results. These statements are hereby identified as "forward-looking statements" for purposes of the safe harbor provided by the Private Securities Litigation Reform Act of 1995. These forward-looking statements involve risks and uncertainties that could cause our results to differ materially from management's current expectations. Actual results and performance can also be influenced by other risks that we face in running our operations including, but are not limited to, general business conditions in the airline industry, changes in demand for our services and products, the timing and amount or cancellation of orders, the price and continuity of supply of component parts used in our operations, the change of control that will occur on the sale by the receiver of the Company's shares held by our previously controlling stockholders, and other risks detailed from time to time in the Company's filings with the Securities Exchange Commission, including, its annual report on form 20-F and its periodic reports on form 6-K. These documents contain and identify other important factors that could cause actual results to differ materially from those contained in our projections or forward-looking statements. Stockholders and other readers are cautioned not to place undue reliance on these forwardlooking statements, which speak only as of the date on which they are made. We undertake no obligation to update publicly or revise any forward-looking statement.
Annex 1- listing smelter or refiner names in supply chain
| Metal | Smelter Name | Smelter Country |
|---|---|---|
| Gold | Faggi Enrico S.p.A. | ITALY |
| Gold | Chimet S.p.A. | ITALY |
| Gold | Allgemeine Gold-und Silberscheideanstalt A.G. | GERMANY |
| Gold | AngloGold Ashanti Córrego do Sítio Minerção | BRAZIL |
| Gold | Argor-Heraeus SA | SWITZERLAND |
| Gold | Asahi Pretec Corporation | JAPAN |
| Gold | Dowa | JAPAN |
| Gold | Eco-System Recycling Co., Ltd. | JAPAN |
| Gold | Heraeus Ltd. Hong Kong | HONG KONG |
| Gold | Heraeus Precious Metals GmbH & Co. KG | GERMANY |
| Gold | Ishifuku Metal Industry Co., Ltd. | JAPAN |
| Gold | Istanbul Gold Refinery | TURKEY |
| Gold | Johnson Matthey Inc | UNITED STATES |
| Gold | Johnson Matthey Ltd | CANADA |
| Gold | JX Nippon Mining & Metals Co., Ltd. | JAPAN |
| Gold | Kennecott Utah Copper LLC | UNITED STATES |
| Gold | Kojima Chemicals Co., Ltd | JAPAN |
| Gold | LS-NIKKO Copper Inc. | KOREA, REPUBLIC OF |
| Gold | Materion | UNITED STATES |
| Gold | Matsuda Sangyo Co., Ltd. | JAPAN |
| Gold | Metalor Technologies (Hong Kong) Ltd | HONG KONG |
| Gold | Metalor Technologies (Singapore) Pte. Ltd. | SINGAPORE |
| Gold | Metalor Technologies SA | SWITZERLAND |
| Gold | Metalor USA Refining Corporation | UNITED STATES |
| Gold | Mitsubishi Materials Corporation | JAPAN |
| Gold | Mitsui Mining and Smelting Co., Ltd. | JAPAN |
| Gold | Nihon Material Co. LTD | JAPAN |
| Gold | Ohio Precious Metals, LLC | UNITED STATES |
| Gold | PAMP SA | SWITZERLAND |
| Gold | Rand Refinery (Pty) Ltd | SOUTH AFRICA |
| Gold | Royal Canadian Mint | CANADA |
| Gold | SEMPSA Joyería Platería SA | SPAIN |
| Gold | Solar Applied Materials Technology Corp. | TAIWAN |
| Metal | Smelter Name | Smelter Country |
|---|---|---|
| Gold | Sumitomo Metal Mining Co., Ltd. | JAPAN |
| Gold | Tanaka Kikinzoku Kogyo K.K. | JAPAN |
| Gold | Tokuriki Honten Co., Ltd | JAPAN |
| Gold | Umicore Precious Metals Thailand | THAILAND |
| Gold | Umicore SA Business Unit Precious Metals Refining | BELGIUM |
| Gold | United Precious Metal Refining, Inc. | UNITED STATES |
| Gold | Valcambi SA | SWITZERLAND |
| Gold | Western Australian Mint trading as The Perth Mint | AUSTRALIA |
| Tantalum | Conghua Tantalum and Niobium Smeltry | CHINA |
| Tantalum | Duoluoshan | CHINA |
| Tantalum | Exotech Inc. | UNITED STATES |
| Tantalum | F&X Electro-Materials Ltd. | CHINA |
| Tantalum | Guangdong Zhiyuan New Material Co., Ltd. | CHINA |
| Tantalum | Hi-Temp | UNITED STATES |
| Tantalum | Jiujiang Tanbre Co., Ltd. | CHINA |
| Tantalum | LSM Brasil S.A. | BRAZIL |
| Tantalum | Mitsui Mining & Smelting | JAPAN |
| Tantalum | Molycorp Silmet A.S. | ESTONIA |
| Tantalum | Ningxia Orient Tantalum Industry Co., Ltd. | CHINA |
| Tantalum | QuantumClean | UNITED STATES |
| Tantalum | RFH Tantalum Smeltry Co., Ltd | CHINA |
| Tantalum | Solikamsk Metal Works | RUSSIAN FEDERATION |
| Tantalum | Taki Chemicals | JAPAN |
| Tantalum | Telex | UNITED STATES |
| Tantalum | Ulba | KAZAKHSTAN |
| Tantalum | Zhuzhou Cement Carbide | CHINA |
| Tin | Alpha | UNITED STATES |
| Tin | Gejiu Non-Ferrous Metal Processing Co. Ltd. | CHINA |
| Tin | Malaysia Smelting Corporation (MSC) | MALAYSIA |
| Tin | Mineração Taboca S.A. | BRAZIL |
| Tin | Minsur | PERU |
| Tin | OMSA | BOLIVIA |
| Tin | PT Bukit Timah | INDONESIA |
| Tin | Thaisarco | THAILAND |
| Metal | Smelter Name | Smelter Country |
|---|---|---|
| Tin | Yunnan Tin Company, Ltd. | CHINA |
| Gold | Advanced Chemical Company | UNITED STATES |
| Gold | Aida Chemical Industries Co., Ltd. | JAPAN |
| Gold | Almalyk Mining and Metallurgical Complex (AMMC) | UZBEKISTAN |
| Gold | Asaka Riken Co., Ltd. | JAPAN |
| Gold | Aurubis AG | GERMANY |
| Gold | Bangko Sentral ng Pilipinas (Central Bank of the Philippines) | PHILIPPINES |
| Gold | Boliden AB | SWEDEN |
| Gold | C. Hafner GmbH + Co. KG | GERMANY |
| Gold | CCR Refinery - Glencore Canada Corporation | CANADA |
| Gold | Cendres + Métaux SA | SWITZERLAND |
| Gold | Daejin Indus Co., Ltd. | KOREA, REPUBLIC OF |
| Gold | Do Sung Corporation | KOREA, REPUBLIC OF |
| Gold | Doduco GmbH | GERMANY |
| Gold | Heimerle + Meule GmbH | GERMANY |
| Gold | Japan Mint | JAPAN |
| Gold | Jiangxi Copper Company Limited | CHINA |
| Gold | JSC Ekaterinburg Non-Ferrous Metal Processing Plant | RUSSIAN FEDERATION |
| Gold | JSC Uralelectromed | RUSSIAN FEDERATION |
| Gold | Kazzinc | KAZAKHSTAN |
| Gold | METALÚRGICA MET-MEX PEÑOLES, S.A. DE C.V | MEXICO |
| Gold | MMTC-PAMP India Pvt., Ltd. | INDIA |
| Gold | Moscow Special Alloys Processing Plant | RUSSIAN FEDERATION |
| Gold | Nadir Metal Rafineri San. Ve Tic. A.?. | TURKEY |
| Gold | Navoi Mining and Metallurgical Combinat | UZBEKISTAN |
| Gold | Ohura Precious Metal Industry Co., Ltd. | JAPAN |
| Gold | OJSC "The Gulidov Krasnoyarsk Non-Ferrous Metals Plant" (OJSC Krastsvetmet) | RUSSIAN FEDERATION |
| Gold | OJSC Novosibirsk Refinery | RUSSIAN FEDERATION |
| Metal | Smelter Name | Smelter Country |
|---|---|---|
| Gold | Prioksky Plant of Non-Ferrous Metals | RUSSIAN FEDERATION |
| Gold | PT Aneka Tambang (Persero) Tbk | INDONESIA |
| Gold | PX Précinox SA | SWITZERLAND |
| Gold | Republic Metals Corporation | UNITED STATES |
| Gold | Samduck Precious Metals | KOREA, REPUBLIC OF |
| Gold | Schone Edelmetaal B.V. | NETHERLANDS |
| Gold | Shandong Zhaojin Gold & Silver Refinery Co., Ltd. | CHINA |
| Gold | Sichuan Tianze Precious Metals Co., Ltd. | CHINA |
| Gold | Singway Technology Co., Ltd. | TAIWAN |
| Gold | Geib Refining Corporation | UNITED STATES |
| Gold | Inner Mongolia Qiankun Gold and Silver Refinery Share Company Limited | CHINA |
| Gold | KGHM Polska Mied? Spó?ka Akcyjna | POLAND |
| Gold | SOE Shyolkovsky Factory of Secondary Precious Metals | RUSSIAN FEDERATION |
| Gold | The Refinery of Shandong Gold Mining Co., Ltd. | CHINA |
| Gold | Torecom | KOREA, REPUBLIC OF |
| Gold | Umicore Brasil Ltda. | BRAZIL |
| Gold | YAMAMOTO PRECIOUS METAL CO., LTD. | JAPAN |
| Gold | Yokohama Metal Co., Ltd. | JAPAN |
| Gold | Zhongyuan Gold Smelter of Zhongjin Gold Corporation | CHINA |
| Gold | Zijin Mining Group Co., Ltd. Gold Refinery | CHINA |
| Tin | An Vinh Joint Stock Mineral Processing Company | VIET NAM |
| Tin | China Tin Group Co., Ltd. | CHINA |
| Tin | Cooperativa Metalurgica de Rondônia Ltda. | BRAZIL |
| Tin | CV Ayi Jaya | INDONESIA |
| Tin | CV Gita Pesona | INDONESIA |
| Tin | CV Serumpun Sebalai | INDONESIA |
| Tin | CV United Smelting | INDONESIA |
| Tin | CV Venus Inti Perkasa | INDONESIA |
| Tin | Dowa | JAPAN |
| Metal | Smelter Name | Smelter Country |
|---|---|---|
| Tin | Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company | VIET NAM |
| Tin | Elmet S.L.U. (Metallo Group) | SPAIN |
| Tin | EM Vinto | BOLIVIA |
| Tin | Fenix Metals | POLAND |
| Tin | Gejiu Kai Meng Industry and Trade LLC | CHINA |
| Tin | Jiangxi Ketai Advanced Material Co., Ltd. | CHINA |
| Tin | Magnu's Minerais Metais e Ligas Ltda. | BRAZIL |
| Tin | Melt Metais e Ligas S/A | BRAZIL |
| Tin | Metallic Resources, Inc. | UNITED STATES |
| Tin | Metallo-Chimique N.V. | BELGIUM |
| Tin | Mitsubishi Materials Corporation | JAPAN |
| Tin | Nghe Tinh Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | O.M. Manufacturing (Thailand) Co., Ltd. | THAILAND |
| Tin | O.M. Manufacturing Philippines, Inc. | Philippines |
| Tin | Phoenix Metal Ltd. | RWANDA |
| Tin | PT Aries Kencana Sejahtera | INDONESIA |
| Tin | PT Artha Cipta Langgeng | INDONESIA |
| Tin | PT ATD Makmur Mandiri Jaya | INDONESIA |
| Tin | PT Babel Inti Perkasa | INDONESIA |
| Tin | PT Bangka Prima Tin | INDONESIA |
| Tin | PT Bangka Tin Industry | INDONESIA |
| Tin | PT Belitung Industri Sejahtera | INDONESIA |
| Tin | PT BilliTin Makmur Lestari | 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 Justindo | INDONESIA |
| Tin | PT Karimun Mining | INDONESIA |
| Tin | PT Mitra Stania Prima | INDONESIA |
| Tin | PT Panca Mega Persada | INDONESIA |
| Tin | PT Prima Timah Utama | INDONESIA |
| Tin | PT Refined Bangka Tin | INDONESIA |
| Tin | PT Sariwiguna Binasentosa | INDONESIA |
| Metal | Smelter Name | Smelter Country |
|---|---|---|
| Tin | PT Stanindo Inti Perkasa | INDONESIA |
| Tin | PT Timah (Persero) Tbk Kundur | INDONESIA |
| Tin | PT Timah (Persero) Tbk Mentok | INDONESIA |
| Tin | PT Tinindo Inter Nusa | INDONESIA |
| Tin | PT Tommy Utama | INDONESIA |
| Tin | PT Wahana Perkit Jaya | INDONESIA |
| Tin | Resind Indústria e Comércio Ltda. | BRAZIL |
| Tin | Rui Da Hung | TAIWAN |
| Tin | Gejiu Yunxin Nonferrous Electrolysis Ltd. | CHINA |
| Tin | Soft Metais Ltda. | BRAZIL |
| Tin | Tuyen Quang Non-Ferrous Metals Joint Stock Company | VIET NAM |
| Tin | VQB Mineral and Trading Group JSC | VIET NAM |
| Tin | White Solder Metalurgia e Mineração Ltda. | BRAZIL |
| Tin | Yunnan Chengfeng Non-ferrous Metals Co., Ltd. | CHINA |
| Tungsten | Hunan Chunchang Nonferrous Metals Co., Ltd. | CHINA |
| Tungsten | Xiamen Tungsten Co., Ltd. | CHINA |
| Tungsten | Guangdong Xianglu Tungsten Co., Ltd. | CHINA |
| Tungsten | Ganzhou Huaxing Tungsten Products Co., Ltd. | CHINA |
| Tungsten | A.L.M.T. TUNGSTEN Corp. | JAPAN |
| Tungsten | Ganzhou Seadragon W & Mo Co., Ltd. | CHINA |
| Tungsten | Wolfram Bergbau und Hütten AG | AUSTRIA |
| Tungsten | Ganzhou Non-ferrous Metals Smelting Co., Ltd. | CHINA |
| Tungsten | H.C. Starck GmbH | GERMANY |
| Tungsten | Kennametal Huntsville | UNITED STATES |
| Tungsten | Global Tungsten & Powders Corp. | UNITED STATES |
| Tin | PT Sumber Jaya Indah | INDONESIA |
| Tantalum | Changsha South Tantalum Niobium Co., Ltd. | CHINA |
| Tantalum | Global Advanced Metals Aizu | JAPAN |
| Tantalum | Global Advanced Metals Boyertown | UNITED STATES |
| Metal | Smelter Name | Smelter Country |
|---|---|---|
| Tantalum | H.C. Starck Co., Ltd. | THAILAND |
| Tantalum | H.C. Starck GmbH Goslar | GERMANY |
| Tantalum | H.C. Starck GmbH Laufenburg | GERMANY |
| Tantalum | H.C. Starck Hermsdorf GmbH | GERMANY |
| Tantalum | H.C. Starck Inc. | UNITED STATES |
| Tantalum | H.C. Starck Ltd. | JAPAN |
| Tantalum | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tantalum | JiuJiang JinXin Nonferrous Metals Co., Ltd. | CHINA |
| Tantalum | KEMET Blue Metals | MEXICO |
| Tantalum | KEMET Blue Powder | UNITED STATES |
| Tantalum | Plansee SE Liezen | AUSTRIA |
| Tantalum | Plansee SE Reutte | AUSTRIA |
| Tungsten | Chenzhou Diamond Tungsten Products Co., Ltd. | CHINA |
| Tungsten | Chongyi Zhangyuan Tungsten Co., Ltd. | CHINA |
| Tungsten | Dayu Weiliang Tungsten Co., Ltd. | CHINA |
| Tungsten | Fujian Jinxin Tungsten Co., Ltd. | CHINA |
| Tungsten | H.C. Starck Smelting GmbH & Co.KG | GERMANY |
| Tungsten | Hunan Chenzhou Mining Group Co., Ltd. | CHINA |
| Tungsten | Japan New Metals Co., Ltd. | JAPAN |
| Tungsten | Jiangxi Xinsheng Tungsten Industry Co., Ltd. | CHINA |
| Tungsten | Kennametal Fallon | UNITED STATES |
| Tungsten | Tejing (Vietnam) Tungsten Co., Ltd. | VIET NAM |
| Tungsten | Xiamen Tungsten (H.C.) Co., Ltd. | CHINA |
| Tin | Chenzhou Yunxiang Mining and Metallurgy Company Limited | CHINA |
| Tantalum | D Block Metals, LLC | UNITED STATES |
| Tantalum | Hengyang King Xing Lifeng New Materials Co., Ltd. | CHINA |
| Tantalum | Mineração Taboca S.A. | BRAZIL |
| Tantalum | Yichun Jin Yang Rare Metal Co., Ltd. | CHINA |
| Tungsten | Hydrometallurg, JSC | RUSSIAN FEDERATION |
| Tungsten | Pobedit, JSC | RUSSIAN FEDERATION |
Annex 2- country of origin
Indonesia recycled Oruro, Potosí, Bolivia China Recycled scrap material Kab. Bangka, Indonesia/ Kab. Bangka Tengah, Indonesia Indonesia Bangka Island, Bangka Nelitung Province Brazil Russia