Executive Order 14415 (July 2026) changes what a waiver takes. From January 1, 2027, waivers generally need an approved mitigation plan, and the requirement flows down to every subcontractor tier.
The three things a plan shows
- The noncompliant source, named. Which part, which magnet, and where in the chain the covered-country step happens.
- Documented efforts to find compliant material. Who you asked, when, and what they said. Alternatives you evaluated and why they did or didn't work.
- A timeline. When you expect to move to compliant material, and the steps in between.
Where the evidence comes from
Most of a good plan is a record you build before you need it:
- An exposure map showing which parts have covered magnets and which are exempt.
- An outreach log showing each supplier contact and response, including "no response."
- Replacement-supplier options with their status and lead times.
How Provenance Defense helps
Our Mitigation Plan Support documents the noncompliant source, your search for compliant material, and replacement-supplier options, per product family. You or your counsel write and submit the plan; we supply the documentation behind it.
This is general information, current as of the review date above. The plan and any submission are yours; talk to your counsel about content and process.