Lumentum Holdings Inc.

06/01/2026 | Press release | Distributed by Public on 06/01/2026 15:28

Specialized Disclosure Report (Form SD)



Lumentum Holdings Inc.

Conflict Minerals Report

For the Calendar Year Ended December 31, 2025

Introduction

Lumentum Holdings Inc. ("we", "our", "Lumentum" or the "Company") is an industry-leading provider of optical and photonic products defined by revenue and market share essential to a range of cloud, artificial intelligence and machine learning ("AI/ML"), telecommunications, consumer, and industrial end-market applications.

Prior to July 2025, we operated in two end-market focused reportable segments, Cloud & Networking and Industrial Tech. Our Cloud & Networking products included a comprehensive portfolio of optical and photonic components, modules, and subsystems supplied to cloud and communications network operators and network equipment manufacturers building cloud data center infrastructure, including products for AI/ML and data center interconnect ("DCI") applications, and communications service provider networks, including products for access (local), metro (intracity), long-haul (city-to-city and worldwide), and submarine (undersea) network infrastructure. Our Cloud & Networking products also supported network equipment manufacturers building enterprise network infrastructure. Demand for our Cloud & Networking products was driven by the rapid growth in cloud and network capacity required for expanding cloud computing and services, including for AI/ML, streaming video and video conferencing, gaming, wireless and mobile devices, and internet of things. Our Industrial Tech products included solid-state lasers, kilowatt-class fiber lasers, diode lasers, ultrafast lasers, and gas lasers, which address applications in numerous end-markets. In the industrial manufacturing end-market, our lasers are incorporated into our customers' manufacturing machine tools used for the precision processing of materials in a range of industries including semiconductor device and microelectronics fabrication, electric vehicle and battery production, metal cutting and welding, and advanced manufacturing. Our lasers also address certain semiconductor inspection and life-science applications. Our products can also be used in the industrial end-market in imaging and sensing systems for process feedback and control, quality assurance, and waste reduction. Adoption of our products in the industrial end-market is driven by the needs of customers to advance semiconductor and microelectronics industry roadmaps, including those that support cloud data center and AI/ML infrastructure, and by Industry 4.0/5.0 trends, including increasing manufacturing precision and flexibility and reducing waste and environmental impact. Demand for our products in the industrial end-market is driven by end-customer investments in manufacturing capacity. In the consumer end-market, our laser light sources are integrated into our customers' 3D sensing cameras, which are used in mobile devices and other consumer electronics devices to enable applications including biometric identification, computational photography and virtual and augmented reality. In the automotive end-market, our lasers are used in our customers' LiDAR and other optical sensor devices, which are being used in advanced driver assistance systems ("ADAS") and in-cabin driver and occupant monitoring systems.

Starting in July 2025, we implemented a re-organization, and we are now managed as a single, integrated enterprise, with a unified management team overseeing operations across the entire company, rather than through discrete operating segments. We disaggregate revenue by type of product, which are Components and Systems, and by geography. A Components product is defined as one of the individual building blocks that goes into creating a larger solution. It is typically not a complete product on its own but rather a specialized element that enables system functionality. This includes semiconductor laser chips, laser sub-assemblies, line subsystems and wavelength management systems. These are supplied to customers who then integrate them into their own full system solutions. Components represent foundational parts that support or enable that system's operation and include a comprehensive portfolio of optical and photonic chips, components, laser light sources that are integrated into smartphones, subsystems supplied to cloud data center operators, AI/ML infrastructure providers, and network equipment manufacturer customers who are building cloud data center and network infrastructures. A Systems product is defined as a complete, stand-alone product that delivers full functionality to the end customer. It is typically self-contained and ready to operate within a customer's network or application environment. This includes optical modules, optical circuit switches, and industrial lasers such as short-pulse solid-state lasers and kilowatt-class fiber lasers. These products integrate multiple technologies and subsystems into a finished solution that directly addresses a customer's needs. A system represents the end-product that can be deployed and used independently.

Lumentum has a global footprint that enables us to address global market opportunities for our products. Lumentum has manufacturing capabilities and facilities in North America, South America, Asia-Pacific, and Europe, with employees engaged in research and development, administration, manufacturing, support and sales and marketing activities. For more information, please refer to Lumentum's Annual Report on Form 10-K for the fiscal year ended June 28, 2025, filed with the U.S. Securities and Exchange Commission ("SEC") on August 19, 2025.

This Report has been prepared in accordance with the requirements of Rule 13p-1 (the "Rule") and Form SD promulgated under the Securities Exchange Act of 1934, as amended. The Rule requires disclosure of certain information when a company manufactures or contracts to manufacture products where the minerals specified in the Rule are necessary to the functionality or production of those products. This Report relates to the process undertaken by Lumentum to exercise due diligence on the source and chain of custody of cassiterite, columbite-tantalite (coltan), gold, wolframite, and their derivatives, which are limited to tin, tantalum and tungsten (collectively, the "Conflict Minerals") contained in Lumentum products that were manufactured, or contracted to be manufactured, during the calendar year 2025. Third-party


products that Lumentum sells but that it does not manufacture or contract to manufacture are outside the scope of this Report. This Report can be found on our website at www.lumentum.com/investors.

Executive Summary

Lumentum reviewed its supplier base to determine which suppliers were supplying Lumentum with parts or materials that were necessary to the functionality or production of the products we manufactured in calendar year 2025 and contained Conflict Minerals. We then contacted these identified suppliers to complete the Conflict Minerals Reporting Template ('CMRT") as part of our reasonable country of origin inquiry ("RCOI"). In connection with the CMRT, these suppliers generally provided us with a list of smelter or refiner names (collectively, "smelters") that may have provided the Conflict Minerals in the parts or materials provided to us. We do not have a direct contractual or business relationship with these smelters, thus we worked closely with our suppliers-in-scope for our RCOI process. Through the RCOI process, 321 unique smelter entities were identified. Of these 321 smelters, 40 were identified as sourcing (or there was a reason to believe they may be sourcing) from the Democratic Republic of Congo (the "DRC") or surrounding countries (collectively, the "Covered Countries"). Lumentum's due diligence review indicates that 31 of the 40 smelters were found to be conformant to a Responsible Minerals Assurance Process (RMAP) as of December 31, 2025. The remaining 9 smelters sourcing from the Covered Countries were reported by a single supplier and were subject to Lumentum's risk mitigation process described below.

Design of Due Diligence

Lumentum designed its due diligence measures to conform to the Organisation for Economic Co-operation and Development ("OECD") Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas: Third Edition (the "OECD Guidance"). The OECD Guidance sets forth five steps for supply chain due diligence. There is significant overlap between our reasonable country of origin inquiry ("RCOI") efforts and our due diligence measures performed, both of which are described below.

Management Systems

Lumentum has established a management system for Conflict Minerals. This included the creation of a Conflict Minerals Team comprised of senior leaders from functional areas of Lumentum impacted by Conflict Minerals. This team was created to support supply chain due diligence and the implementation and monitoring of an effective Conflict Minerals program. We have a grievance mechanism through which our employees and suppliers can report a violation of our policies and maintain an e-mail address [email protected] for suppliers and employees to report violations, ask questions and voice concerns. We established a system of controls over our mineral supply chain, including the RCOI and due diligence procedures described below. All relevant Conflict Minerals data is kept in our internal database system.

Reasonable Country of Origin Inquiry

Lumentum conducted a RCOI that was designed to include all suppliers and original manufacturers that supplied parts or materials that contained Conflict Minerals and were necessary to the functionality or production of the products we manufactured in calendar year 2025. We conducted the RCOI in accordance with the due diligence processes. As part of our RCOI, we contacted approximately 272 in-scope suppliers, representing those most relevant based on spend. Each direct supplier was asked to provide Conflict Minerals data in the Responsible Minerals Initiative ("RMI") Conflict Minerals Reporting Template ("CMRT"). Greater than 90% of these suppliers responded. Non-responsive suppliers and suppliers with inadequate responses were contacted multiple times. After this RCOI review, 321 smelters were identified as Conflict Minerals smelters consistent with the smelter definitions agreed upon by industry and the audit protocols published by the RMI. After performing a risk assessment on each of the 321 smelters regarding their responses, 40 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information directly from the suppliers as well as other public information available at the time. In accordance with the Rule, Lumentum is required to exercise due diligence on the Conflict Minerals' source and chain of custody and to follow a nationally or internationally recognized due diligence framework.

Conflict Minerals Policy

Lumentum's Conflict Minerals Policy is publicly available on our website at: https://www.lumentum.com/en/company/sustainability/our-business.

Risk Assessment and Response

Lumentum's risk assessment plan was designed to define, identify, mitigate, and manage risks. Risks that arise are reported to the designated member of senior management. As described above under Reasonable Country of Origin Inquiry, Lumentum identified the smelters in its supply and performed a risk assessment for 321 smelters. 40 smelters either confirmed that they are sourcing Conflict Minerals from the Covered Countries, or there was reason to believe they source Conflict Minerals from the Covered Countries. This assessment was based on information obtained directly from the smelters as well as other public information available at the time. Lumentum then compared the


identified smelter list to the list provided by the RMI and for smelters that were not identified as RMAP conformant, Lumentum conducted risk mitigation. 229 of 321 identified smelters (greater than 70%) were RMAP conformant or actively engaged in the RMAP audit process. These smelters were also reviewed against publicly available information to determine if there was any reason to believe that they directly or indirectly finance or benefit armed groups in the Covered Countries.

Due Diligence Results and Ongoing Risk Mitigation Efforts

Smelters

Of the 40 smelters that either confirmed they source Conflict Minerals from the Covered Countries or Lumentum has reason to believe source Conflict Minerals from the Covered Countries, 31 smelters were found to be RMAP conformant and 9 smelters (Al Etihad Gold Refinery DMCC, Augmont Enterprises Private Limited, Dijllah Gold Refinery FZC, Emirates Gold DMCC, Fidelity Printers and Refiners Ltd., Fujairah Gold FZC, International Precious Metal Refiners, SAM Precious Metals FZ-LLC, Shirpur Gold Refinery Ltd.) were not RMAP Conformant at the end of 2025. Accordingly, Lumentum is continuing its risk mitigation efforts in accordance with the OECD Due Diligence Guidance, including engagement with the sole supplier that has reported these 9 smelters in its CMRT, to determine whether these smelters are actually used in the manufacture of products procured by Lumentum. A complete list of the identified smelters likely used in our supply chain is provided in Annex A hereto.

Steps to be Taken to Mitigate Risk

Lumentum is committed to continuous improvement in our due diligence process to further mitigate the risk that the necessary Conflict Minerals in our products could benefit armed groups in the Covered Countries. As part of our efforts to mitigate this risk, new or renewed supplier contracts require suppliers to provide information that will allow us to evaluate their Conflict Minerals status. Additionally, we are continuing to engage with and educate our suppliers to increase supplier response rates and improve the timeliness, accuracy and comprehensiveness of the supplier survey responses we receive. We are also continuing to work with our suppliers to encourage them to source from certified smelters when sourcing material from the Covered Countries.

Given that we are a downstream company, many steps removed from the mining or processing of 3TG, and that we do not purchase raw ore or refined 3TG, Lumentum relies on independent third-party audits of smelters and refiners. Lumentum supports such independent third-party audits, including those conducted by the RMAP, through our financial support for the RMI. Lumentum also actively supports the goal of increasing smelter and refiner participation in the RMAP through our participation in the RMI and direct outreach to those smelters and encourage them to participate in the RMAP.

Additional Risk Factors

The statements included in this Conflict Minerals Report are based on the RCOI process and due diligence performed in good faith by Lumentum. These statements are based on the information available at the time. A number of factors could introduce errors or otherwise affect our determinations regarding the status of our supply chain with respect to Conflict Minerals. These factors include, but are not limited to: (i) gaps in supplier or smelter data, (ii) errors or omissions by suppliers or smelters, (iii) uncertainty or varied interpretations of the disclosure requirements described in the SEC final rules, (iv) all instances of conflict minerals necessary to the functionality or manufacturing of our products may not have been reported correctly by our suppliers, (v) many suppliers and smelters are unfamiliar with the diligence process and information required to be provided due to this new regulation, which could lead to inaccurate responses, (vi) timeliness of data received from our suppliers, (vii) information that is in the public domain may not be discovered despite having conducted a reasonable search, (viii) there may be errors in publicly available information, (ix) language barriers or errors in translation could lead to inaccurate information, (x) there could be oversights or errors in smelter audits, (xi) materials sourced from the Covered Countries could inaccurately be declared secondary materials, (xii) illegally tagged Conflict Minerals could be introduced into our supply chain without our knowledge or the knowledge of our suppliers, (xiii) difficulties obtaining information from companies that are no longer in business and (xiv) smuggling of Conflict Minerals outside the Covered Countries may make identification of their origin more difficult. This Specialized Disclosure Report on Form SD contains forward looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These statements include any plans or intentions to improve the number and quality of supplier and smelter response rates and steps we intend to take to mitigate risk in our supply chain. These forward-looking statements involve risks and uncertainties that could cause actual results to differ materially from those projected. In particular, Lumentum's actions and the results of those actions may be affected by: (a) changes in global regulations related to the extraction of and disclosure obligations related to Conflict Minerals; (b) the ability of our direct suppliers and smelters to provide accurate information in response to our requests; (c) the availability of alternate sources of materials necessary to the functionality or production of our products on commercially reasonable terms or at all; (d) the ability of certified smelters to meet demand for raw materials; and (e) limits on our ability to unilaterally influence supplier behavior. These forward-looking statements are made as of the date hereof and the Lumentum assumes no obligation to update such statements.



Annex A

Smelters and Refineries

Below is a list of the smelters reported to Lumentum as likely in Lumentum's supply chain as of December 31, 2025.

Metal Smelter Name
Gold Advanced Chemical Company
Gold Aida Chemical Industries Co., Ltd.
Gold Agosi AG
Gold Almalyk Mining and Metallurgical Complex (AMMC)
Gold AngloGold Ashanti Corrego do Sitio Mineracao
Gold Argor-Heraeus S.A.
Gold ASAHI METALFINE, Inc.
Gold Asaka Riken Co., Ltd.
Gold Atasay Kuyumculuk Sanayi Ve Ticaret A.S.
Gold Aurubis AG, Hamburg
Gold Bangko Sentral ng Pilipinas (Central Bank of the Philippines)
Gold Boliden Mineral AB (Ronnskar)
Gold C. Hafner GmbH + Co. KG
Gold Caridad
Gold Glencore Canada Corporation - CCR Refinery
Gold Cendres + Metaux S.A.
Gold Yunnan Copper Southwest Copper Branch
Gold Chimet S.p.A.
Gold Chugai Mining
Gold DSC (Do Sung Corporation)
Gold Dowa
Gold Eco-System Recycling Co., Ltd. East Plant
Gold Hangzhou Fuchunjiang Smelting Co., Ltd.
Gold LT Metal Ltd.
Gold Heimerle + Meule GmbH
Gold Heraeus Metals Hong Kong Ltd.
Gold Heraeus Germany GmbH Co. KG
Gold Hunan Chenzhou Mining Co., Ltd.
Gold Hunan Guiyang yinxing Nonferrous Smelting Co., Ltd.
Gold HwaSeong CJ CO., LTD.
Gold Inner Mongolia Qiankun Gold and Silver Refinery Share Co., Ltd.
Gold Ishifuku Metal Industry Co., Ltd.
Gold Istanbul Gold Refinery
Gold Japan Mint
Gold Jiangxi Copper Co., Ltd.
Gold Asahi Refining USA Inc.
Gold Asahi Refining Canada Ltd.
Gold JX Advanced Metals Corporation
Gold Kazakhmys Smelting LLC
Gold Kazzinc Ltd
Gold Kennecott Utah Copper LLC
Gold Kojima Chemicals Co., Ltd.


Gold Kyrgyzaltyn JSC
Gold LS MnM Inc.
Gold Materion
Gold Matsuda Sangyo Co., Ltd.
Gold Metalor Technologies (Suzhou) Ltd.
Gold Metalor Technologies (Hong Kong) Ltd.
Gold Metalor Technologies (Singapore) Pte., Ltd.
Gold Metalor Technologies S.A.
Gold Metalor USA Refining Corporation
Gold Metalurgica Met-Mex Penoles S.A. De C.V.
Gold Mitsubishi Materials Corporation
Gold Mitsui Mining and Smelting Co., Ltd.
Gold Nadir Metal Rafineri San. Ve Tic. A.S.
Gold Navoi Mining and Metallurgical Combinat
Gold Nihon Material Co., Ltd.
Gold Ohura Precious Metal Industry Co., Ltd.
Gold MKS PAMP SA
Gold Penglai Penggang Gold Industry Co., Ltd.
Gold PT Aneka Tambang (Persero) Tbk
Gold PX Precinox S.A.
Gold Rand Refinery (Pty) Ltd.
Gold Royal Canadian Mint
Gold Sabin Metal Corp.
Gold Samduck Precious Metals
Gold Samwon Metals Corp.
Gold SEMPSA Joyeria Plateria S.A.
Gold Shandong Tiancheng Biological Gold Industrial Co., Ltd.
Gold Shandong Zhaojin Gold & Silver Refinery Co., Ltd.
Gold Sichuan Tianze Precious Metals Co., Ltd.
Gold Solar Applied Materials Technology Corp.
Gold Sumitomo Metal Mining Co., Ltd.
Gold Super Dragon Technology Co., Ltd.
Gold Tanaka Kikinzoku Kogyo K.K.
Gold Great Wall Precious Metals Co., Ltd. of CBPM
Gold Shandong Gold Smelting Co., Ltd.
Gold Tokuriki Honten Co., Ltd.
Gold Tongling Nonferrous Jinguan (Ausmelt) Copper Industry
Gold Torecom
Gold Umicore S.A. Business Unit Precious Metals Refining
Gold United Precious Metal Refining, Inc.
Gold Valcambi S.A.
Gold Gold Corporation - The Perth Mint
Gold Yamakin Co., Ltd.
Gold Yokohama Metal Co., Ltd.
Gold Zhongyuan Gold Smelter of Zhongjin Gold Corporation
Gold Zijin Mining Group Gold Smelting Co. Ltd.
Gold Morris and Watson


Gold SAFINA A.S.
Gold Umicore Precious Metals Thailand
Gold MMTC-PAMP India Pvt., Ltd.
Gold KGHM Polska Miedz Spolka Akcyjna
Gold Fidelity Printers and Refiners Ltd.
Gold Singway Technology Co., Ltd.
Gold Shandong Humon Smelting Co., Ltd.
Gold Shenzhen Zhonghenglong Real Industry Co., Ltd.
Gold Al Etihad Gold Refinery DMCC
Gold Emirates Gold DMCC
Gold International Precious Metal Refiners
Gold T.C.A S.p.A
Gold REMONDIS PMR B.V.
Gold Fujairah Gold FZC
Gold Shirpur Gold Refinery Ltd.
Gold Korea Zinc Co., Ltd.
Gold Marsam Metals
Gold TOO Tau-Ken-Altyn
Gold Abington Reldan Metals, LLC
Gold Shenzhen CuiLu Gold Co., Ltd.
Gold Albino Mountinho Lda.
Gold SAAMP
Gold L'Orfebre S.A.
Gold 8853 S.p.A.
Gold Italpreziosi
Gold WIELAND Edelmetalle GmbH
Gold Oegussa Oesterreichische Gold- und Silber-Scheideanstalt Gesm.b.H.
Gold AU Traders and Refiners
Gold GGC Gujrat Gold Centre Pvt. Ltd.
Gold Modeltech Sdn Bhd
Gold Bangalore Refinery
Gold Degussa Sonne / Mond Goldhandel GmbH
Gold Pease & Curren
Gold JALAN & Company
Gold SungEel HiMetal Co., Ltd.
Gold Planta Recuperadora de Metales SpA
Gold ABC Refinery Pty Ltd.
Gold Safimet S.p.A
Gold State Research Institute Center for Physical Sciences and Technology
Gold Gold Coast Refinery
Gold NH Recytech Company
Gold QG Refining, LLC
Gold Dijllah Gold Refinery FZC
Gold CGR Metalloys Pvt Ltd.
Gold Sovereign Metals
Gold Eco-System Recycling Co., Ltd. North Plant
Gold Eco-System Recycling Co., Ltd. West Plant


Gold Augmont Enterprises Private Limited
Gold Kundan Care Products Ltd.
Gold Emerald Jewel Industry India Limited (Unit 1)
Gold Emerald Jewel Industry India Limited (Unit 2)
Gold Emerald Jewel Industry India Limited (Unit 3)
Gold Emerald Jewel Industry India Limited (Unit 4)
Gold K.A. Rasmussen
Gold Alexy Metals
Gold MD Overseas
Gold Metallix Refining Inc.
Gold Metal Concentrators SA (Pty) Ltd.
Gold WEEEREFINING
Gold Gold by Gold Colombia
Gold Dongwu Gold Group
Gold SAM Precious Metals FZ-LLC
Gold Coimpa Industrial LTDA
Gold SHENZHEN JINJUNWEI RESOURCE COMPREHENSIVE DEVELOPMENT CO., LTD.
Gold TITAN COMPANY LIMITED, JEWELLERY DIVISION
Gold GG Refinery Ltd.
Gold Impala Platinum - Base Metal Refinery (BMR)
Gold Impala Platinum - Rustenburg Smelter
Gold SOLEIL METALS (Chala One Plant)
Gold SOLEIL METALS (YAKARI Plant)
Gold Impala Platinum - Platinum Metals Refinery (PMR)
Gold Elite Industech Co., Ltd.
Gold Minera Titan del Peru SRL (MTP) - Belen Plant
Tantalum Changsha South Tantalum Niobium Co., Ltd.
Tantalum Guangdong Rising Rare Metals-EO Materials Ltd.
Tantalum F&X Electro-Materials Ltd.
Tantalum XIMEI RESOURCES (GUANGDONG) LIMITED
Tantalum JiuJiang JinXin Nonferrous Metals Co., Ltd.
Tantalum Jiujiang Tanbre Co., Ltd.
Tantalum JX Advanced Metals Corporation
Tantalum AMG Brasil
Tantalum Metallurgical Products India Pvt., Ltd.
Tantalum Mineracao Taboca S.A.
Tantalum Mitsui Kinzoku Company, Limited
Tantalum NPM Silmet AS
Tantalum Ningxia Orient Tantalum Industry Co., Ltd.
Tantalum QuantumClean
Tantalum Yanling Jincheng Tantalum & Niobium Co., Ltd.
Tantalum Taki Chemical Co., Ltd.
Tantalum Telex Metals
Tantalum Ulba Metallurgical Plant JSC
Tantalum Hengyang King Xing Lifeng New Materials Co., Ltd.
Tantalum D Block Metals, LLC
Tantalum FIR Metals & Resource Ltd.


Tantalum Jiujiang Zhongao Tantalum & Niobium Co., Ltd.
Tantalum XinXing HaoRong Electronic Material Co., Ltd.
Tantalum Jiangxi Dinghai Tantalum & Niobium Co., Ltd.
Tantalum KEMET de Mexico
Tantalum TANIOBIS Co., Ltd.
Tantalum TANIOBIS GmbH
Tantalum QSIL Metals Hermsdorf GmbH
Tantalum Materion Newton Inc.
Tantalum TANIOBIS Japan Co., Ltd.
Tantalum TANIOBIS Smelting GmbH & Co. KG
Tantalum Global Advanced Metals Boyertown
Tantalum Global Advanced Metals Aizu
Tantalum Resind Industria e Comercio Ltda.
Tantalum Jiangxi Tuohong New Raw Material
Tantalum RFH Yancheng Jinye New Material Technology Co., Ltd.
Tantalum XIMEI RESOURCES(GUIZHOU) TECHNOLOGY CO., LTD.
Tantalum PowerX Ltd.
Tantalum CMT Rare Metal Advanced Materials (Hunan) Co., Ltd.
Tantalum Jiangxi Suns Nonferrous Materials Co. Ltd.
Tin Chenzhou Yunxiang Mining and Metallurgy Co., Ltd.
Tin Alpha Assembly Solutions Inc
Tin PT Aries Kencana Sejahtera
Tin PT Premium Tin Indonesia
Tin Dongguan Best Alloys Co., Ltd.
Tin Dowa
Tin Empresa Metallurgica Vinto
Tin Estanho de Rondonia S.A.
Tin Feinhutte Halsbrucke GmbH
Tin Fenix Metals
Tin Gejiu Non-Ferrous Metal Processing Co., Ltd.
Tin Gejiu Zili Mining And Metallurgy Co., Ltd.
Tin Jean Goldschmidt International (JGI Hydrometal)
Tin Gejiu Kai Meng Industry and Trade LLC
Tin China Tin Group Co., Ltd.
Tin Metallic Resources, Inc.
Tin Mineracao Taboca S.A.
Tin Minsur
Tin Mitsubishi Materials Corporation
Tin Jiangxi New Nanshan Technology Ltd.
Tin O.M. Manufacturing (Thailand) Co., Ltd.
Tin Operaciones Metalurgicas S.A.
Tin PT Artha Cipta Langgeng
Tin PT Mitra Stania Prima
Tin PT Prima Timah Utama
Tin PT Refined Bangka Tin
Tin PT Sariwiguna Binasentosa
Tin PT Stanindo Inti Perkasa


Tin PT Timah Tbk Kundur
Tin PT Timah Tbk Mentok
Tin PT Tinindo Inter Nusa
Tin Rui Da Hung
Tin Soft Metais Ltda.
Tin Thaisarco
Tin Gejiu Yunxin Nonferrous Electrolysis Co., Ltd.
Tin VQB Mineral and Trading Group JSC
Tin White Solder Metalurgia e Mineracao Ltda.
Tin Yunnan Chengfeng Non-ferrous Metals Co., Ltd.
Tin Tin Smelting Branch of Yunnan Tin Co., Ltd.
Tin CV Venus Inti Perkasa
Tin Magnu's Minerais Metais e Ligas Ltda.
Tin Melt Metais e Ligas S.A.
Tin PT ATD Makmur Mandiri Jaya
Tin O.M. Manufacturing Philippines, Inc.
Tin CV Ayi Jaya
Tin Electro-Mechanical Facility of the Cao Bang Minerals & Metallurgy Joint Stock Company
Tin Nghe Tinh Non-Ferrous Metals Joint Stock Company
Tin PT Rajehan Ariq
Tin PT Cipta Persada Mulia
Tin An Vinh Joint Stock Mineral Processing Company
Tin Resind Industria e Comercio Ltda.
Tin Super Ligas
Tin Aurubis Beerse
Tin Aurubis Berango
Tin PT Bangka Prima Tin
Tin HuiChang Hill Tin Industry Co., Ltd.
Tin Modeltech Sdn Bhd
Tin Guangdong Hanhe Non-ferrous Metal Limited Company
Tin Chifeng Dajingzi Tin Industry Co., Ltd.
Tin Tin Technology & Refining
Tin Dongguan CiEXPO Environmental Engineering Co., Ltd.
Tin Ma'anshan Weitai Tin Co., Ltd.
Tin PT Masbro Alam Stania
Tin Luna Smelter, Ltd.
Tin Yunnan Yunfan Non-ferrous Metals Co., Ltd.
Tin Precious Minerals and Smelting Limited
Tin Gejiu City Fuxiang Industry and Trade Co., Ltd.
Tin PT Mitra Sukses Globalindo
Tin TRATHO Metal Quimica
Tin CRM Fundicao De Metais E Comercio De Equipamentos Eletronicos Do Brasil Ltda
Tin CRM Synergies EMEA, S.L.U.
Tin Fabrica Auricchio Industria e Comercio Ltda.
Tin PT Putera Sarana Shakti (PT PSS)
Tin Mining Minerals Resources SARL
Tin Takehara PVD Materials Plant / PVD Materials Division of MITSUI MINING & SMELTING CO., LTD.


Tin Malaysia Smelting Corporation Berhad (Port Klang)
Tin Woodcross Smelting Company Limited
Tin Global Advanced Metals Greenbushes Pty Ltd.
Tin PT Arsed Indonesia
Tin P Kay Metal, Inc
Tungsten A.L.M.T. Corp.
Tungsten Kennametal Huntsville
Tungsten Guangdong Xianglu Tungsten Co., Ltd.
Tungsten Chongyi Zhangyuan Tungsten Co., Ltd.
Tungsten Global Tungsten & Powders LLC
Tungsten Japan New Metals Co., Ltd.
Tungsten Kennametal Fallon
Tungsten Wolfram Bergbau und Hutten AG
Tungsten Xiamen Tungsten Co., Ltd.
Tungsten Ganzhou Jiangwu Ferrotungsten Co., Ltd.
Tungsten Jiangxi Yaosheng Tungsten Co., Ltd.
Tungsten Jiangxi Xinsheng Tungsten Industry Co., Ltd.
Tungsten Jiangxi Tonggu Non-ferrous Metallurgical & Chemical Co., Ltd.
Tungsten Malipo Haiyu Tungsten Co., Ltd.
Tungsten Xiamen Tungsten (H.C.) Co., Ltd.
Tungsten Jiangxi Gan Bei Tungsten Co., Ltd.
Tungsten Ganzhou Seadragon W & Mo Co., Ltd.
Tungsten Asia Tungsten Products Vietnam Ltd.
Tungsten Hunan Shizhuyuan Nonferrous Metals Co., Ltd. Chenzhou Tungsten Products Branch
Tungsten H.C. Starck Tungsten GmbH
Tungsten TANIOBIS Smelting GmbH & Co. KG
Tungsten Masan High-Tech Materials
Tungsten Jiangwu H.C. Starck Tungsten Products Co., Ltd.
Tungsten Niagara Refining LLC
Tungsten China Molybdenum Tungsten Co., Ltd.
Tungsten Philippine Chuangxin Industrial Co., Inc.
Tungsten Lianyou Metals Co., Ltd.
Tungsten Hubei Green Tungsten Co., Ltd.
Tungsten Cronimet Brasil Ltda
Tungsten Fujian Xinlu Tungsten Co., Ltd.
Tungsten Tungsten Vietnam Joint Stock Company
Tungsten Plansee Composite Materials GmbH
Tungsten Lianyou Resources Co., Ltd.
Tungsten Shinwon Tungsten (Fujian Shanghang) Co., Ltd.
Tungsten KENEE MINING VIETNAM COMPANY LIMITED
Tungsten Philippine Bonway Manufacturing Industrial Corporation
Tungsten Jing Yuan Tungsten Technology Co., Ltd.
Tungsten S.P.T. spol.s r.o.
Tungsten Tungamoy Metals Inc.
40 of the smelters above declared to be sourcing, or there was reason to believe they may be sourcing, from the Covered Countries. Under the Rule, the requirement is to identify whether or not a smelter is sourcing from the Covered Countries and there is no requirement to identify the specific Covered Country by smelter. Given the limitation on the specificity of the smelters' disclosures, the Covered Countries potentially associated with the reported smelters, based on the available information, were the DRC, Rwanda, Burundi, Tanzania, and Uganda.

Lumentum Holdings Inc. published this content on June 01, 2026, and is solely responsible for the information contained herein. Distributed via EDGAR on June 01, 2026 at 21:29 UTC. If you believe the information included in the content is inaccurate or outdated and requires editing or removal, please contact us at [email protected]