Commercially available off-the-shelf (COTS) items are excepted from the magnet restriction, unless the item is 50% or more magnet by weight.
Two questions, per part
- Is it really COTS? Sold in substantial quantities in the commercial marketplace, and bought without modification? A catalog sensor usually is. A motor wound to your spec, a magnet assembly made to your drawing, or a "standard" part with a custom option often isn't.
- Is it 50% or more magnet by weight? Compare the weight of the covered magnet (NdFeB or SmCo) with the weight of the whole item. Most motors, speakers and sensors are well under half. A bare magnet, a magnetic coupling, or a holding magnet assembly may not be.
Where suppliers get stuck
- Weight data. Datasheets rarely give magnet weight. You may need the manufacturer to state it, or a teardown estimate for an assumption you can defend.
- Variants. One base part number can have custom suffixes. Treat each purchased part number on its own.
- Distributor descriptions. "Commercial" in a catalog isn't the same thing as COTS under the rule.
What we document
In a Stage 1 Exposure Map, each part we mark as COTS-exempt carries the reasoning: why it's off-the-shelf, the magnet type, and the weight basis we used, with the source. If we can't support the exception, the part goes on the tracing list instead.
This is general information about the rule, current as of the review date above. Whether an exception applies to your part is your decision; talk to your counsel where it's unclear.