Method 0.4 · Release 11 · deployed September 13, 2026, 00:07 UTC (September 12, 8:07 p.m. ET)
Dataset last updated: September 12, 2026

Critical-mineral origin evidence

Prove where your tantalum and tungsten come from.

From January 1, 2027, defense contracts bar tantalum, tungsten and certain rare-earth magnets mined, refined, separated, melted or produced in China, Russia, North Korea or Iran.

CMMS-BS starts with what public disclosures establish: a published method and a benchmark of 128 company-mineral profiles, with full tantalum and tungsten assessments. Its governance protocol, which traces each production stage to a supplier's own documents, opens to clients when Highbrow Group begins commercial operations.

128company-mineral profiles
58organizations
60 / 60critical minerals · USGS 2025 list
12full tantalum and tungsten assessments
12upstream relationship records

What changes in 2027

AuthorityChangeTiming
DFARS 252.225-7052
10 U.S.C. § 4872
The restriction expands from material “melted or produced” in a covered country to material “mined, refined, separated, melted, or produced” there.January 1, 2027
Executive Order 14415, § 2Routine waivers under 10 U.S.C. 4872(c)(1) end, except under an accepted mitigation plan.January 1, 2027
Executive Order 14415, § 3Guidance requiring contractors at any tier to map supply chains “from raw materials to the end use products,” with an indentured bill of materials traced “back to the origin of raw materials.”Due by January 16, 2027

Applicability, exceptions and implementation requirements are set out in the official texts.

How the governance protocol works

  1. 01Scope the question

    Define the entity, product, mineral and period.

  2. 02Map every document

    Match each source to the question it supports.

  3. 03Mark each stage

    Evidenced, Unknown or Not applicable.

  4. 04Record the decision

    Assign owners and explain the decision and its limits.

Inspect the published results

All 128 profiles →
● A 6● B 4○ Unrated 117⚑ Review hold 1
Tantalum and tungsten results · 12 assessments
Tantalum and tungsten disclosure assessments · research date 2026-09-12
OrganizationMineralRoleScoreBandCoverageConfidence
Cisco SystemsTantalumElectronics92● A100%Moderate
Cisco SystemsTungstenElectronics92● A100%Moderate
HP Inc.TantalumElectronics92● A100%Moderate
HP Inc.TungstenElectronics92● A100%Moderate
Dell TechnologiesTantalumElectronics83● B100%Moderate
Dell TechnologiesTungstenElectronics83● B100%Moderate
Vishay IntertechnologyTantalumComponents92● A100%Moderate
Vishay IntertechnologyTungstenComponents92● A100%Moderate
Global Advanced MetalsTantalumUpstream83● B100%Moderate
TANIOBIS GmbHTantalumUpstreamWithheld○ Unrated83%Limited
Source undated
KennametalTungstenUpstream75● B100%Moderate
H.C. Starck TungstenTungstenUpstreamWithheld○ Unrated67%Limited
Source undated
Coverage below 80%

Named companies have not endorsed or participated in this research.

CMMS-BS assesses what public sourcing disclosures establish. It is not a certification, an audit or legal advice.

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