What happens on January 1, 2027?
DoD contracts can't include NdFeB or SmCo magnets whose material was mined, refined, separated, melted or produced in China, Russia, North Korea or Iran, unless an exception applies.
Does it apply to us if we're a subcontractor?
Expect it to. The clause flows down, and under EO 14415 the mitigation-plan requirement for waivers flows to every subcontractor tier.
What should we do first?
Find out which purchased parts contain covered magnets, and which of those are exempt. That's the Exposure Map: about two weeks from an accepted, cleaned parts list.
Do we need to send drawings or specs?
No. We work from a cleaned purchased-parts list: manufacturer, part number, generic description, supplier. No program names, assemblies, drawings, specs, quantities, prices, CUI or ITAR/EAR technical data.
How long does tracing take?
It depends on suppliers. We use a defined effort per supplier (for example, 3 emails and 2 calls over 4 weeks), so the timeline is predictable even when answers aren't.
What if a supplier never answers?
That's a result, and we record it. "No response" after a defined effort goes in the outreach log, which also helps document your efforts for a mitigation plan.
Will you tell us whether we're compliant?
No. We give you the evidence; you make the compliance determination. We're not a law firm, a certifier or a government body.
See the Deadline Tracker for related dates.
This is general information, current as of the review date above. Check your contract and talk to your counsel about how the rule applies to you.