Rare Earth Directory

Policy

DFARS 252.225-7052: the Jan 1, 2027 rare earth sourcing deadline

DFARS 252.225-7052 is a Department of War contract clause that bars contractors from delivering samarium-cobalt and neodymium-iron-boron magnets, and certain tantalum and tungsten products, made in or from material mined, refined or separated in China, Russia, Iran or North Korea. Today the bar starts at melting; from Jan 1, 2027 it reaches back to the mine.

The clause carries 10 U.S.C. 4872 into contracts. Defense contractors were reported in May 2026 to be asking for a second delay. Executive Order 14415 of Jul 20, 2026 instead limits waivers from Jan 1, 2027, and the sources checked show no change to the date.

Verified through Oct 1, 2026

What changes Jan 1, 2027Who is affected

At a glance

Clause
DFARS 252.225-7052, clause date May 2024, carrying 10 U.S.C. 4872
Applies to
Department of War contracts and subcontracts at every tier that deliver a covered material or an end item containing one
Through Dec 31, 2026
No covered material melted or produced in a covered country
From Jan 1, 2027
No covered material mined, refined, separated, melted or produced in a covered country
Waivers
Nonavailability and national security waivers remain, with a formal mitigation plan required from Jan 1, 2027
Full clause takes effect
Jan 12027: mine-to-magnet reach
Covered countries
4China, Russia, Iran, North Korea
Covered materials in the clause
5Two magnet types, tantalum, tungsten powder, tungsten heavy alloy
Executive Order 14415
Jul 202026: limits on waivers

What is DFARS 252.225-7052?

DFARS 252.225-7052 is the clause that carries 10 U.S.C. 4872 into Department of War contracts. It tells a contractor not to deliver covered materials, or end items containing them, that come from China, Russia, Iran or North Korea, and it must be passed down to every subcontractor that supplies a covered material.

The clause lists five covered materials: samarium-cobalt magnets, neodymium-iron-boron magnets, tantalum metals and alloys, tungsten metal powder, and tungsten heavy alloy or finished and semi-finished parts containing it. The statute has since added molybdenum, which the clause does not yet list, and gallium and germanium take effect on Dec 18, 2027, according to Holland & Knight.

The clause is a contract term, not a tariff or an import ban. It governs what a defense contractor may deliver to the Department of War.

What changes on Jan 1, 2027?

On Jan 1, 2027 the clause stops looking only at where a magnet or metal was melted and made and starts looking at where its raw material was mined, refined and separated. For neodymium-iron-boron magnets the bar covers the entire supply chain from mining neodymium, iron and boron through finished magnets.

The clause before and after Jan 1, 2027
What Through Dec 31, 2026 From Jan 1, 2027
The prohibition No covered material melted or produced in a covered country, and no end item made in a covered country that contains one. No covered material mined, refined, separated, melted or produced in a covered country, and no end item made in a covered country that contains one.
NdFeB magnets Melting neodymium with iron and boron into alloy, and every later step: powder, pressing, sintering or bonding, magnetization. The entire supply chain, from mining neodymium, iron and boron through finished magnets.
SmCo magnets Melting samarium with cobalt into alloy, and every later step. The entire supply chain, from mining or producing cobalt and samarium ore or feedstock, including recycled material, through finished magnets.
Tantalum Reduction or melting of tantalum into metal, and later steps. Mining or producing tantalum ore or feedstock, including recycled material, through metals and alloys.
Tungsten Atomization, calcination and reduction, consolidation, and later steps. Mining or producing tungsten ore or feedstock, including recycled material, through powders and heavy alloy.
Off-the-shelf items The exception does not cover an item that is 50 percent or more tungsten by weight. The exception does not cover an item that is 50 percent or more covered material by weight.

If any listed stage happened in a covered country, the material is covered. A magnet made in the US from ore separated in China would not qualify from Jan 1, 2027.

What exceptions and waivers does the rule have?

The clause does not apply to commercially available off-the-shelf end items (with a 50 percent covered-material limit from 2027), to electronic devices unless a contract says otherwise, to uncombined mill products from 2027, or to neodymium-iron-boron magnets made from recycled material if the milling and sintering happen in the United States. A nonavailability determination can also excuse a delivery.

Exceptions in paragraph (c) of the clause, as published on acquisition.gov
ExceptionWhat the clause saysNotes
Off-the-shelf end itemsA commercial product sold in substantial quantities and offered to the government without modification.Not excepted if 50 percent or more tungsten by weight (through 2026) or 50 percent or more covered material by weight (from Jan 1, 2027).
Electronic devicesAn item that operates by controlling the flow of electrons or other charged particles in circuits.Excepted unless the contract says otherwise. Executive Order 14415 tells the Secretary of War to review how this exception is applied.
Mill products (from Jan 1, 2027)A covered material that is a mill product, such as bar, billet, slab, wire, plate or sheet, not yet incorporated into an end item, subsystem, assembly or component.Relevant to tantalum and tungsten more than to magnets.
Recycled NdFeB magnetsA neodymium-iron-boron magnet manufactured from recycled material if the milling of the recycled material and the sintering of the final magnet take place in the United States.Relevant to makers of magnets from recycled material. The statute's newer recycled-material exception for SmCo magnets is not yet written into the clause.
Nonavailability determinationAn official finds that compliant covered material of satisfactory quality and quantity cannot be procured as and when needed at a reasonable price.The waiver most affected by Executive Order 14415.

Source: the clause text on acquisition.gov (May 2024) and the Holland & Knight summary of Executive Order 14415.

What does Executive Order 14415 change about the deadline?

Executive Order 14415, signed Jul 20, 2026, does not move the Jan 1, 2027 date. It tells the Secretary of War to stop issuing nonavailability waivers from that day unless the contractor submits a formal mitigation plan, and it adds supply chain mapping and alternative-source requirements with deadlines running to Apr 2027.

A mitigation plan must identify the noncompliant source, document exhaustive efforts to obtain compliant material, describe how the noncompliant material will leave the supply chain and set a strict timeline. Failing to qualify a domestic source does not by itself prove nonavailability unless the contractor shows active, adequately funded and ongoing efforts to qualify one.

Section 6 says nothing in the order impairs Project Vault, purchases from foreign projects financed or insured by EXIM or the DFC, or purchases from companies supported by the Departments of State, War, Commerce or Energy. It is a statement about this order, not a waiver of the clause.

Dates that matter, in order
  1. May 30, 2024 Clause republished with the 2027 phase History The Defense Acquisition Regulations System amends the clause in the Federal Register (89 FR 46821), keeping the Jan 1, 2027 step to the full supply chain.
  2. Dec 2025 FY2026 defense authorization act History Adds molybdenum to the statute and sets Dec 18, 2027 for gallium and germanium (Holland & Knight).
  3. May 2026 Contractors reported to seek a second delay Reported The Financial Times reported that major defense contractors were lobbying for a postponement, according to Adamas Intelligence. The Pentagon's response is not reported in the sources checked.
  4. Jul 20, 2026 Executive Order 14415 is signed Signed Restricts waivers, requires supply chain mapping to the origin of raw materials and requires alternative sources.
  5. Oct 18, 2026 Source qualification strategy due Next Within 90 days the Secretary of War must develop a strategy to speed up testing and qualification of new sources and materials.
  6. Jan 1, 2027 The clause takes full effect; waivers narrow Next Mined, refined and separated stages are covered, the off-the-shelf exception narrows, and waivers need an accepted mitigation plan.
  7. Jan 16, 2027 Mapping policy, remedies list and alternative-source action due Next Within 180 days the Secretary must issue supply chain mapping and illumination policy and guidance, start regulatory action on alternative sources and give the White House a list of remedies for knowing noncompliance.
  8. Apr 16, 2027 Implementing regulations due Next Within 90 days of finishing the mapping guidance, if it is finished on time.
  9. Dec 18, 2027 Gallium and germanium become covered materials Next The statute's later additions take effect.

Who is affected by the DFARS 2027 rule?

Every contractor that delivers covered materials to the Department of War, and every subcontractor in its chain, must be able to show that a magnet or metal was not mined, refined, separated or made in a covered country. That makes US miners, separators, metal makers and magnet makers the suppliers defense buyers will look for.

Who the rule touches, and US capacity named in this directory
RoleWhy it mattersExamples in this directory
Defense primes and subcontractorsThey deliver the end items and must pass the clause down. Executive Order 14415 adds bills of materials that trace parts back to the origin of raw materials.Not profiled here; see US magnet manufacturers for their suppliers.
Magnet makersA magnet must trace to a mine, a separator and an alloy maker outside the covered countries.MP Materials, USA Rare Earth, eVAC Magnetics, Vulcan Elements, Noveon Magnetics, Arnold Magnetic Technologies
Metal and alloy makersMetal is the step between oxide and magnet.Phoenix Tailings, REalloys (company-reported DFARS qualification effort)
SeparatorsSeparation is a stage the clause names, so separated oxide must also come from outside the covered countries.Mountain Pass, White Mesa Mill
Miners and developersFrom 2027 the mine itself counts.US rare earth mines, miners and developers

Capacity and customer details are on each profile. The directory does not certify any company as compliant with the clause.

Could the Jan 1, 2027 deadline be delayed?

The sources checked show no change to the date as of Oct 1, 2026. The Financial Times reported in May 2026 that major defense contractors were lobbying for a second delay, and the Center for Strategic and International Studies is reported to have said in Apr 2026 that adhering to the rule may not be feasible without much more capacity. The July order limits waivers instead.

The statute carries the Jan 1, 2027 step, so a change would need action beyond a contract clause. The directory will log any change on the updates page.

Which US projects, companies and states does this touch?

The pages below carry the figures, the sources and the dates for each project or company named here.

Questions about the DFARS 2027 rare earth rule

What is DFARS 252.225-7052?

It is the Defense Federal Acquisition Regulation Supplement clause that implements 10 U.S.C. 4872 for magnets, tantalum and tungsten. It bars contractors from delivering covered materials from China, Russia, Iran or North Korea, and it must be passed down to subcontractors.

What does the Jan 1, 2027 rare earth rule ban?

From Jan 1, 2027 a contractor may not deliver a covered material mined, refined, separated, melted or produced in a covered country. For NdFeB magnets that covers the entire supply chain from mining neodymium, iron and boron through finished magnets.

Which countries are covered?

The clause covers North Korea, China, Russia and Iran. Executive Order 14415 defines an unreliable foreign supplier as one under the foreign ownership, control or influence of those nations or others the Secretary designates.

Does the rule cover consumer or commercial products?

It covers deliveries under Department of War contracts and subcontracts at any tier, including subcontracts for commercial products, unless an exception applies. It does not regulate sales to customers outside defense work.

Are recycled magnets excepted?

A neodymium-iron-boron magnet made from recycled material is excepted if the milling of the recycled material and the sintering of the final magnet take place in the United States. The statute's newer recycled exception for samarium cobalt is not yet in the clause.

Has the deadline been delayed?

Not in the sources checked as of Oct 1, 2026. Defense contractors were reported in May 2026 to be seeking a second delay, and Executive Order 14415 of Jul 20, 2026 limits waivers from Jan 1, 2027 instead of postponing the date.

What does Executive Order 14415 require?

It limits nonavailability waivers from Jan 1, 2027 to those backed by a mitigation plan, and requires supply chain mapping to raw materials, supplier vetting and alternative sources, with deadlines of Oct 18, 2026, Jan 16, 2027 and Apr 16, 2027.

Sources and verification

Each profile lists its sources, a confidence grade and a verification date. Order of authority: official records (SEC filings, agency documents), company documents and technical reports, research papers, then independent press. Syndicated copies and reference works are labeled and are never the only source for a number. Company-reported figures are labeled as such, and non-binding deals are labeled "letter of intent" or "conditional".

Tags show what kind of source each link is. How sources are ranked

Policy and funding

Which other policy explainers are there?

Nine explainers cover the foreign controls, defense rules, permitting steps and funding programs behind the projects in this directory.