Magnets, tantalum and tungsten from covered countries

← All Insights

1. The covered materials rule

Section 225.7018 of the Defense Federal Acquisition Regulation Supplement (DFARS) implements 10 U.S.C. 4872, a restriction on certain magnets, tantalum and tungsten (DFARS 225.7018-0). Covered material means samarium-cobalt magnets, neodymium-iron-boron magnets, tantalum metals and alloys, tungsten metal powder, and tungsten heavy alloy (DFARS 225.7018-1). Any finished or semi-finished component containing tungsten heavy alloy is also covered material.

Tungsten heavy alloy is a tungsten base pseudo alloy that meets ASTM B777 or SAE-AMS-T-21014 for a particular class (DFARS 225.7018-1). An alloy also qualifies if it contains at least 90 percent tungsten in a matrix of other metals, such as nickel-iron or nickel-copper, with a density of at least 16.5 grams per cubic centimeter. The restriction is tied to covered countries, which DFARS 225.7001 defines by reference to 10 U.S.C. 4872 and 4875 (DFARS 225.7001). The definition names four countries. The section uses the same end item definition as the specialty metals rules: the final production product when assembled or completed and ready for delivery under a line item.

2. Two regimes, before and after 1 January 2027

Through 31 December 2026, the Department may not acquire covered material melted or produced in a covered country (DFARS 225.7018-2(a)(1)). Nor may it acquire an end item manufactured in a covered country that contains covered material. From 1 January 2027, the restriction widens to covered material mined, refined, separated, melted or produced in a covered country (DFARS 225.7018-2(a)(2)). The end item rule continues unchanged. The later rule rests on section 854 of Public Law 118-31.

For the two magnet types, the restriction through 2026 covers melting the alloy and every later phase of production (DFARS 225.7018-2(b)(1)). The later phases include powder formation, pressing, sintering or bonding, and magnetization. From 2027, subject to the exceptions, it covers the entire supply chain through finished magnets: for samarium-cobalt from mining or producing ore or feedstock, including recycled material, and for neodymium-iron-boron from mining (DFARS 225.7018-2(b)(2) and DFARS 225.7018-2(b)(4)). The restriction on melting and producing samarium-cobalt magnets is in addition to any applicable specialty metals melting restrictions (DFARS 225.7018-2(b)(3)).

For tantalum, the restriction through 2026 covers reducing or melting any form of tantalum into metal, including unwrought metal, powder, mill products and alloys, and all later phases (DFARS 225.7018-2(c)(1)). From 2027 it starts with mining or producing tantalum ore or feedstock, including recycled material (DFARS 225.7018-2(c)(2)). For tungsten metal powder and tungsten heavy alloy, the restriction through 2026 covers atomization, calcination and reduction into powder, final consolidation of non-melt derived powders, and all later phases (DFARS 225.7018-2(d)(1)). From 2027 it starts with mining or producing tungsten ore or feedstock (DFARS 225.7018-2(d)(2)).

3. Exceptions

The restriction does not apply to acquisitions at or below the simplified acquisition threshold (DFARS 225.7018-3(a)). It does not apply to acquisitions outside the United States of items for use outside the United States (DFARS 225.7018-3(b)). It also does not apply to three kinds of end item containing covered material (DFARS 225.7018-3(c)).

The first is a commercially available off-the-shelf (COTS) item, with limits and with guidance on commercially available samarium-cobalt magnets in the DFARS procedures, guidance and information (DFARS 225.7018-3(c)(1)). The exception does not cover a COTS item that is 50 percent or more tungsten by weight through 2026, or 50 percent or more covered material by weight from 2027. It also does not cover mill products, such as bar, billet, slab, wire, cube, sphere, block, blank, plate or sheet, not yet built into an end item, subsystem, assembly or component. Through 2026 that limit covers tantalum and tungsten heavy alloy mill products, and from 2027 any covered material mill product.

The second is an electronic device, which operates by controlling the flow of electrons or other charged particles in circuits (DFARS 225.7018-3(c)(2) and DFARS 225.7018-1). The exception does not apply to a particular device if the Secretary of Defense, on the Strategic and Critical Materials Board of Directors’ recommendation, determines its domestic availability is critical to national security. The third is a neodymium-iron-boron magnet made from recycled material, if milling the recycled material and sintering the final magnet take place in the United States (DFARS 225.7018-3(c)(3)).

4. Nonavailability

The restriction also lifts where the authorized official finds compliant covered materials cannot be procured as needed at a reasonable price (DFARS 225.7018-3(d)). The finding is about satisfactory quality and quantity in the required form. For tantalum metal, tantalum alloy or tungsten heavy alloy, required form means the form and grade of the mill product, or a finished component, needed for the end item (DFARS 225.7018-3(d)(1)). For the two magnet types, it means the form and properties of the magnets (DFARS 225.7018-3(d)(2)).

The head of the contracting activity may make an individual determination that applies to only one contract (DFARS 225.7018-4(a)(1)). The requiring activity must provide a written analysis and certification describing, with specificity, why alternatives that avoid a determination are unacceptable (DFARS 225.7018-4(a)(2)). Copies of individual determinations, and notice of requests that were denied, go to the Deputy Assistant Secretary of Defense for Industrial Policy (DFARS 225.7018-4(a)(3)).

A class determination for more than one contract needs the approval of the Under Secretary of Defense for Acquisition and Sustainment (DFARS 225.7018-4(b)). At least 30 days before making one, the Under Secretary will, to the maximum extent practicable, publish notice on SAM.gov and seek information from interested parties, including producers of covered material mill products (DFARS 225.7018-4(b)(1)). Both steps are taken consistently with protecting national security and confidential business information. The determination and its rationale are made public to the extent national security and confidential business information allow (DFARS 225.7018-4(b)(2)).

5. The clause

Contracts above the simplified acquisition threshold use the clause at DFARS 252.225-7052, Restriction on Acquisition of Certain Magnets, Tantalum, and Tungsten (DFARS 225.7018-5). The clause is not used where items are acquired outside the United States for use outside it, or a nonavailability determination has been made. The specialty metals rules that can apply alongside it are covered in what counts as a specialty metal.

Key terms

Covered material	Samarium-cobalt and neodymium-iron-boron magnets, tantalum, tungsten powder and tungsten heavy alloy.
Covered country	One of four countries defined in DFARS 225.7001 under 10 U.S.C. 4872 and 4875.
Whole supply chain rule	From 1 January 2027, the restriction starts at mining or feedstock.
Tungsten heavy alloy	At least 90 percent tungsten in a metal matrix, density at least 16.5 g/cm3, or a listed specification.
DFARS 252.225-7052	The clause for covered materials above the simplified acquisition threshold.

Every statement above links to the document behind it. The full source list for this piece is on the sources page.

This page describes public United States government programs for general information. It is not legal, regulatory or procurement advice, and it does not address the facts of any particular case.

How Sentfore supports this

Material sourcing rules shape what can be delivered and when. Sentfore works at the delivery end of defense programs in difficult environments, providing secure movement, protective security, facilities and life support. Requirements can be sent through the contact page.