Highlights
- Starting January 1, 2027, DFARS restricts covered-country involvement across the entire rare-earth supply chain—from mining through finished NdFeB and samarium-cobalt magnets.
- China, Russia, Iran, and North Korea are covered countries, and Executive Order 14415 tightens the waiver process by requiring formal, funded mitigation plans.
- Most U.S. and allied mine-to-magnet projects are still commissioning, scaling, or qualifying—meaning industrial timelines don't align with the 2027 compliance deadline.
- Provenance documentation—proving where material was mined, processed, and manufactured—may prove as difficult as physically sourcing compliant material.
- REEx proposes a 'Supply-Chain IND' framework where contractors document funded transition plans to bridge the gap between legal deadlines and industrial reality.
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