DFARS 252.225-7052 includes an exception for electronic devices. It's one of the most useful exceptions, and one of the easiest to over-apply.
Why the definition matters
The clause uses its own definition of "electronic device." Your engineers' everyday sense of the term may be broader. Read the definition in the clause version in your contract, and compare each part against it.
Typical gray areas:
- Sensors (Hall-effect, encoders, magnetic switches): often electronic, but the magnet may be a separate purchased component.
- Motors: a bare motor may not qualify; a motor with integrated drive electronics might.
- Speakers, buzzers, relays and solenoids: electromechanical. Check each against the definition rather than assuming.
- Magnet sub-assemblies sold on their own: generally not electronic devices.
How to handle it
- Record the part's function and construction from the datasheet.
- Note where the magnet sits: inside the device, or bought separately.
- Write down the reasoning for applying (or not applying) the exception.
- If it's unclear, keep the part on the tracing list until you decide.
What we document
In the Exposure Map, every "electronic device" call comes with the reasoning and the source. Parts we can't place clearly are flagged for your decision, not quietly exempted.
This is general information about the rule, current as of the review date above. Applying an exception is your decision; talk to your counsel for an interpretation of the definition.