On January 1, 2027, the covered-materials clause already signed into DoD contracts escalates by its own terms: "melted or produced" becomes "mined, refined, separated, melted, or produced." Origin proof moves back to the mine — for the magnets, tungsten, and tantalum sitting in motors, actuators, seekers, and airframes at every subcontract tier. No new rulemaking is coming to save the date. We build the file that survives it.
Every figure on this page traces to primary text — the clause, the statute, the executive order, the public waiver record. Ask for the citation file on the first call and you will have it before the second.
Most compliance deadlines arrive by rulemaking. This one doesn't need to: the covered-materials clause sits in essentially every DoD contract above the simplified acquisition threshold, and its own text escalates on January 1, 2027 — from restricting covered material melted or produced in North Korea, China, Russia, or Iran, to restricting material mined, refined, separated, melted, or produced there. The obligation flows down to subcontracts for items containing a covered material, commercial products included, with no dollar threshold on the flowdown.
The same day, the waiver door narrows. Under Executive Order 14415, covered-materials waivers stop issuing unless the contractor files a formal mitigation plan — the noncompliant source identified, exhaustive sourcing efforts documented, removal steps described, a strict timeline attached. And the statute behind it reaches prime contracts and subcontracts at any tier.
Here is what the record says about waivers as a strategy: six national-security waivers of the specialty-metals rule have ever been approved since 2009. The escape hatch is not a plan. The origin file is the plan.
Proving where a magnet's ore was mined is precisely as hard as it sounds — the evidence sits with smelters, refiners, and mills three tiers below your purchase order, in countries that publish nothing, held by suppliers with no incentive to volunteer it. That is not a gap in your procurement organization. It is a discipline of its own, and it is the only thing this practice does.
| Material | Where it hides in the BOM | The wrinkle nobody briefs you on |
|---|---|---|
| SmCosamarium-cobalt magnets | TWTs, isolators, circulators, RF assemblies, gyros, high-temp motors | Double-covered. Even where the electronic-device exception applies, SmCo is recaptured by the specialty-metals clause — the "electronic component" exemption expressly excludes high-performance magnets. There is no electronics shelter for SmCo. |
| NdFeBneodymium-iron-boron magnets | Motors, actuators, generators, fin controls, gimbals, seekers | The workhorse magnet of every electromechanical system on the platform — and the material with a usable exception: recycled NdFeB milled and sintered in the US qualifies. Proving the feedstock is recycled is an origin-evidence problem. |
| Wtungsten powder & heavy alloy | Penetrators, counterweights, EFP liners, balance weights, radiation shielding | Heavy alloy is defined to the spec — ≥90% tungsten, density ≥16.5 g/cm³ — and any finished or semi-finished component containing it is captured. The restriction follows the alloy into the part. |
| Tatantalum metals & alloys | Superalloy turbine hot sections, mill products, sputtering targets, energetics | Capacitors — the biggest tantalum volume — mostly exit through the electronic-device exception. What stays in is the hard part: superalloys and energetics, where the melt-source paper trail is thinnest. |
| Ga · Gedecember 18, 2027 | GaN radar and EW amplifiers, GaAs RF, germanium thermal-imaging optics | The second wave, already enacted. China's own export controls on both make the sourcing question urgent before the compliance question even arrives. Build the file once, ahead of the date. |
Tantalum and tungsten already sit on your conflict-minerals form. The other covered materials do not — and this deadline is harder than anything Dodd-Frank 1502 ever asked of you.
Your CMRT program proved the discipline works: smelter-level origin documentation, at scale, under audit. This is the same discipline pointed at a longer list, with a contract clause behind it instead of a disclosure rule — and a waiver record that says nobody is coming to excuse the gap.
Every engagement below is the same underlying product — origin evidence, built from records your supplier didn't write — packaged to the obligation that makes it urgent.
Two weeks. Your BOM screened against the five covered materials and the exceptions that actually apply — SAT, COTS, electronic-device, recycled-feedstock — with the double-coverage traps flagged and a documented risk-factor assessment of where your January 1 exposure genuinely sits. Half credits against the engagement that follows. The diagnostic also sets your fixed fee.
The core product: per-material, per-line documentary origin evidence built backward from your part to the mill, the refiner, and where the clause demands it, the mine — mill certificates, smelter documentation, customs records, and written supplier confirmations, cross-checked against records that would have to be jointly falsified to deceive anyone. Issued at a stated assurance level under the Group's published Protocol, with the limits of the inquiry stated on the file.
After January 1, a covered-materials waiver is only issued against a formal mitigation plan — noncompliant source identified, exhaustive sourcing efforts documented, removal steps, a strict timeline. Waivers run 36 months at the statutory maximum, which makes every waiver a renewal file with a clock on it. We build the plan as an evidence package: the sourcing record that proves "exhaustive" rather than asserts it.
The statute's own words: recycled tantalum, tungsten, or molybdenum qualifies if the contractor "demonstrates to the Secretary" that the recycled material was produced outside a covered nation and processed in qualifying countries. A demonstration to the Secretary is a documentary evidence product — it is literally the thing we make. Same for US-milled recycled NdFeB and SmCo.
On October 1, 2027, DoD procurement closes to batteries produced by six named entities — CATL, BYD, Envision, EVE, Gotion, Hithium — and the implementing regulation defining what evidence satisfies the prohibition does not exist yet. That vacuum is the reason to build the record now: entity screening through the ownership chain, cell provenance documented, before your contracting officer asks the question the rule never answered.
The same monitoring engine that watches federal registers daily for the Group's clients, aimed at your commodity: the implementing rulemakings as they land, the electronic-device-exception review, waiver-acceptance reporting, and the sources-sought and DMSMS traffic that says a program office is looking for exactly what you make. Annual re-verification keeps the evidence file current — because a supplier acquisition three tiers down can change your answer without changing your purchase order.
Ore has no accent. Origin is proved on paper — by documents created under penalty for other purposes, cross-checked until the story either holds or tears.
Mill test certificates name the melt source. Customs entries name the shipper and origin. Smelter and refiner documentation — the same class of evidence your conflict-minerals program already collects — names the feedstock. None of these documents was written to answer our question, which is exactly why they can.
Does the mill cert's melt source match the customs record? Does the refiner's stated capacity make physical sense for the claimed volume? Does the corporate registry confirm who owns the smelter? Records that would have to be jointly falsified are the strongest evidence there is. Inconsistency is the finding.
Written confirmation from the named upstream supplier — the external-confirmation procedure any auditor recognizes on sight. Where covered-nation processing sits in the chain and publishes nothing, direct confirmation is not corroboration. It is the primary evidence, and we scope it accordingly.
An origin file that cannot state its own limits is a guess on letterhead. Ours carry a stated assurance level under the Group's published Protocol — documented, independently verified, or continuously monitored — so the party relying on the file knows precisely how far the evidence goes. That candor is why the file survives the audit that follows the detention, the dispute, or the DCMA question.
Half this market is sold on urgency nobody checked. Every line below is marked — clause text already in force, statute with a date, executive directive, or rule that does not exist yet. The vacuum rows are the interesting ones: the obligation is real, the evidence standard is unwritten, and whoever documents first sets the bar.
| Date | Instrument | Status | Who it reaches |
|---|---|---|---|
| Oct 7, 2026 | DFARS case report due on the battery-exclusion implementing rule — the first signal of what §154 evidence will look like | Pending rule | Anyone with the six named battery entities in the supply chain |
| Jan 1, 2027 | Covered-materials escalation: "melted or produced" → "mined, refined, separated, melted, or produced" — written into signed clause text; no further rulemaking required | Clause in force | DoD contracts above the SAT; flows to subcontracts for items containing a covered material, commercial products included |
| Jan 1, 2027 | Covered-materials waivers cease to issue absent a formal mitigation plan; statutory maximum 36 months per waiver | Directive | Any contractor relying on a covered-materials waiver |
| Jan 1, 2027 | Printed-circuit-board sourcing prohibition takes effect — with the implementing rule still at the advance-notice stage: a live obligation with no written evidence standard | Law · rule vacuum | DoD contractors delivering covered PCB assemblies |
| Jun 30, 2027 | §805 contracting prohibition tied to the 1260H Chinese-military-companies list bites its second stage — no drafted rule | Law · rule vacuum | DoD contractors with 1260H-listed entities in the chain |
| Oct 1, 2027 | Battery procurement closes to six named entities — CATL, BYD, Envision, EVE, Gotion, Hithium — with no implementing clause yet issued | Law · rule vacuum | DoD procurement; every program with those cells in the chain |
| Dec 18, 2027 | Gallium and germanium join the covered-materials restriction — the second wave, already enacted | Law | GaN/GaAs RF and germanium optics supply chains |
| Jan 1, 2028 | The interim national-security waiver that rewards supply-chain illumination and self-disclosure expires — the statutory grace period for getting your file in order has an end date | Law | Contractors who could have used it and didn't |
Statuses verified against primary text — the clause, the statutes, the executive order — and reviewed on a standing cycle. We will not price an engagement against a rule that does not exist; we will absolutely price one against a clause you have already signed.
Every engagement opens with the fixed-fee Materials Diagnostic — two weeks, $7,500 to $15,000 by scope — which establishes which covered materials actually sit in your deliverables, which exceptions genuinely apply, and where the evidence gap is. Half credits against the engagement that follows, and the diagnostic sets your fixed number: a published base plus itemized, objective scope adders, so the price reads as computed, not negotiated.
Published fees are fixed and are not discounted — not for volume, not for speed, not for the promise of more work later. Outside costs — laboratories, inspection firms, customs counsel — are billed to you directly at actuals, without markup. We never hold client funds.
Two weeks and a fixed fee to know exactly which covered materials sit in your deliverables, which exceptions actually protect you, and what evidence stands behind the clause you have already signed.
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