Origin requirements

Covered materials

Trace each production stage to the evidence that supports it.

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.

Materials

  • Samarium-cobalt magnets
  • Neodymium-iron-boron magnets
  • Tantalum metals and alloys
  • Tungsten metal powder
  • Tungsten heavy alloy and parts containing it

Covered countries

  • North Korea
  • China
  • Russia
  • Iran

Stages to evidence

  1. Mining or feedstock
    Including recycled
  2. Refining and separation
  3. Melting or production
  4. Component

What evidence shows what

  • Mill test reports

    Where the metal was melted or produced.

  • Smelter or refiner identification

    Who refined it, not the mine of origin.

  • Stage-by-stage supplier origin declarations

  • Purchase orders and lot traceability

  • Recycler documentation

  • Import and customs records

This page explains the rule; it is not legal advice.

The broader research universe · 60 critical minerals