The rule includes an exception for recycled NdFeB that is milled and sintered in the United States. It matters because domestic recycled magnet capacity is one of the faster ways to a compliant supply.
What has to be true
- The magnet material is recycled NdFeB.
- It was milled in the US.
- It was sintered in the US.
All three have to hold for the magnet in your purchased part, not just for the supplier in general.
Evidence that holds up
- A supplier statement identifying the material as recycled, for the specific grade.
- Records of where milling and sintering happen, for the lot or production period you buy from.
- A link from that magnet to your part: the magnet maker → the component maker → your purchased part number.
The last link is where most files break. The magnet producer can document its process, but if your motor supplier also buys magnets elsewhere, you need to know which magnets went into your parts.
How we approach it
When a supplier points to recycled material, we ask for the documents above, check them against public information about the producer's facilities, and record how strong the chain is. See the Supplier Directory for producers that publicly describe recycled NdFeB production. It's public information, not an endorsement; verify with the supplier.
This is general information about the rule, current as of the review date above. Whether the exception applies is your decision; talk to your counsel where it's unclear.