It can reach lower tiers
Primes and higher-tier suppliers may flow the clause down and ask for supporting information about origin.
FOR DEFENSE MOTOR & ACTUATOR SUPPLIERS · DFARS 252.225-7052
Know what your magnet-origin evidence supports.
Lodeline is a supply-chain evidence service for small and midsize defense suppliers, starting with motor and actuator makers. We collect your supplier documentation for magnets, tungsten and tantalum, map it stage by stage, and show you what is documented, what is missing, and what to ask for next.
30 minutes · No obligation · No drawings or controlled data needed
/ What we do
Your supplier evidence,
organised by stage.
01 / Map
Find the parts in scope
Starting with motors and actuators.
From your part list, we identify which parts are likely to contain NdFeB or SmCo magnets, tungsten or tantalum, and which suppliers sit behind them.
02 / Review
Read what suppliers send
Each document, matched to a stage.
We request and review declarations and certificates, record which production stage each one speaks to, and note where a stage has no document or a covered country appears.
03 / Report
Get a clear evidence pack
Documented, missing, next questions.
A per-part record your quality and contracts teams can review, with the source behind every entry and a list of what to request from each supplier.
Lodeline provides supply-chain documentation and analysis, not legal advice or government certification. Applicability, exceptions, and acceptance depend on the contract and the responsible reviewer.
/ Why it matters
Upstream stages are
hard to see.
Rare earth supply is concentrated, and the further back you go, the less a finished-part declaration usually says. That is why evidence for earlier stages takes time to gather.
01 / Mining
69%
China's share of world rare earth mine production, 2025
About 270,000 of 390,000 tons (rare-earth-oxide equivalent). Source: USGS Mineral Commodity Summaries 2026.
02 / Refining
~91%
China's share of rare earth refining
03 / Date
2027
Upstream stages come into scope
From 1 January 2027 the clause reaches mining, refining and separation, not only melting and production. See sources.
/ The rule
What the clause
looks at.
DFARS 252.225-7052 restricts delivery to the Department of Defense of certain magnets (NdFeB and SmCo), tungsten and tantalum, and of end items containing them, where covered stages took place in China, Russia, Iran or North Korea. Through 31 December 2026 it covers material melted or produced in those countries. From 1 January 2027 it also covers material mined, refined or separated there. The clause includes exceptions, and contractors are expected to include it in qualifying subcontracts.
01MineDocument on file
02SeparateDocument on file
03Metal & alloyNo document yet
04MagnetDeclaration on file
?Open questionRequest alloy-stage record
Earlier stages need records
Separation and metal-making are often several tiers away from you. Records for those stages usually have to be requested, not found.
Waivers are tightening
A July 2026 executive order directs DoD to stop issuing certain waivers for covered materials from 1 January 2027. See sources.
Lodeline provides supply-chain documentation and analysis, not legal advice or government certification. Applicability, exceptions, and acceptance depend on the contract and the responsible reviewer.
Not sure the clause
reaches your parts?
We will talk through which parts are likely in scope and which records to ask for first.
Book a readiness call
Take the 6-question check
30 minutes · No obligation · No drawings or controlled data needed
/ How we work
How an engagement
runs.
- 01
Agree the scope
We agree which parts and suppliers are included, the timeline and a fixed fee before any work begins.
- 02
Map the parts
From part numbers and material descriptions, we identify items likely to contain covered magnets, tungsten or tantalum.
- 03
Request documents
We prepare origin questions for your suppliers and, with your approval, follow up on the answers.
- 04
Review by stage
Each document is matched to the production stage it describes, with its date and issuer recorded.
- 05
Mark the gaps
Stages with no document, unclear wording, or a covered country are listed in plain English with the question to ask.
- 06
Hand over the pack
You receive an evidence pack for your own review and for the questions your customer may ask.
/ Live demo
Screen a parts list
in seconds.
Run the first step of our process on a fictional motor and actuator parts list, or paste your own part descriptions. It flags parts likely to contain covered magnets, tungsten or tantalum, and the upstream stages that still need a supplier document.
/ What you receive
An evidence pack
you can review.
Each part gets one record your quality and contracts teams can check: the production stages, what each document says about them, and what is still missing.
- Stage-by-stage record with facility and country where documented
- Status per stage: documented, partly documented, or no document
- A document register with issuer, date and the stage each covers
- Open questions to send to each supplier
- Stated limits, so nobody reads more into it than it supports
Fictional demonstration3 parts reviewed
Rotor magnet assemblyExample part · NdFeB
All stages documentedMineSeparationAlloyMagnet
Position sensorExample part · SmCo
Gaps openMine · no documentSeparation · no documentAlloyMagnet
Brake actuatorExample part · NdFeB
Covered country indicatedMine · no documentSeparation · covered countryAlloyMagnet
Fictional demonstration — not a supplier verification, certification, or customer result.
Want a pack like this
for your parts?
A pilot covers a small set of your highest-priority parts, scoped and priced before any work begins.
Book a readiness call
See the full sample
30 minutes · No obligation · No drawings or controlled data needed
/ Who we serve
Starting with
motors and actuators.
We focus first on small and midsize suppliers of motors and actuators, where permanent magnets are common and records sit several tiers back. Tap an industry to see where covered material shows up and how we help.
/ Readiness check
Where do you stand?
Six questions.
You get two separate results: how many signs suggest the clause may reach your parts, and how much upstream documentation you appear to have. Your answers stay in this page. They are not sent, saved or added to the address bar.
/ Working with us
Clear limits,
stated up front.
No controlled data
We work from part numbers, material descriptions and supplier origin documents. Please never send drawings, controlled technical data or export-controlled information.
Every entry sourced
Each statement in an evidence pack points to the document it comes from, or says plainly that there is none.
Not a certification
An evidence pack describes documents. It is not a government certification and does not decide whether a part is acceptable. That decision belongs to the responsible reviewer.
/ Engagement
Start with a pilot.
Decide from there.
Pilot review
Fixed-fee pilot, scoped before work begins
A review of a small set of your highest-priority parts, delivered as an evidence pack, so you can see the method and the output before deciding on anything further.
- Part list review for covered materials
- Supplier origin questions prepared
- Stage-by-stage review of documents received
- Evidence pack with gaps and next questions
Ongoing updates
Only if the pilot is useful to you
Extend the same review to more parts, and refresh records when suppliers or documents change. Scope and fee are agreed separately.
- More parts and suppliers
- Refresh when documents change
- New parts as you take on work
/ Not ready for a call?
Get the readiness
checklist.
A short checklist of the questions to answer before a customer asks about DFARS 252.225-7052: which parts are in scope, which stages your records cover, and what to request from suppliers.
- Printable, with a PDF download
- Plain English, no legal jargon
- Works for motors, actuators and other magnet parts
/ FAQ
Common
questions.
Does this rule apply to my company?
It may, if your products reach the Department of Defense, directly or through a prime, and contain NdFeB or SmCo magnets, tungsten or tantalum. Whether it applies, and whether an exception is available, depends on the specific contract and the responsible reviewer. A readiness call can help you work out which questions to ask.
We already have a supplier declaration. Isn't that enough?
It depends on what it says. Many declarations describe the finished part or the magnet maker only. From 1 January 2027 the clause also looks at mining, refining and separation, so it helps to know which stages your documents actually cover.
Does recycled material count?
It depends on the material and the stage. From 1 January 2027 the clause's upstream restriction refers to ore and feedstock, including recycled material, for several covered materials, so where recycled feed came from can matter. The statute also contains a narrow exception for NdFeB magnets made from recycled material when milling and sintering take place in the United States, and some later statutory changes may not yet appear in the DFARS clause. Whether any exception applies to your parts is a question for the contract and the responsible reviewer.
How long does a pilot take?
Most of the time goes into waiting for supplier responses. We agree a timeline as part of the scope before work begins.
What if a stage shows a covered country or has no document?
The evidence pack says so plainly, names the document (or the lack of one), and lists the question to put to the supplier. What happens next is a decision for you, your customer and the responsible reviewer.
Do you need our drawings or controlled data?
No. We work from part numbers, material descriptions and supplier origin documents. Please do not send drawings, controlled technical data, contract files or export-controlled information.
Is this legal advice or a certification?
No. Lodeline provides supply-chain documentation and analysis, not legal advice or government certification. Applicability, exceptions, and acceptance depend on the contract and the responsible reviewer.
/ Sources
Where these
facts come from.
- DFARS 252.225-7052, Restriction on the Acquisition of Certain Magnets, Tantalum, and Tungsten (clause dated May 2024). Restriction on material melted or produced in a covered country through 31 December 2026; mined, refined, separated, melted, or produced from 1 January 2027.
- Federal Register, final rule published 30 May 2024.
- 10 U.S.C. 4872, Acquisition of sensitive materials from non-allied foreign nations, including the recycled NdFeB magnet exception.
- Executive order signed 20 July 2026 (Federal Register, 23 July 2026), on waivers for covered materials from 1 January 2027.
- USGS Mineral Commodity Summaries 2026: Rare Earths.
- IEA Global Critical Minerals Outlook 2025.
Sources checked 15 October 2026. Regulations change; always confirm the clause version in your contract.
/ Get started
Request a
readiness call.
Tell us what you supply. On the call we will talk through which parts may be in scope, what documentation you already have, and whether a scoped, fixed-fee pilot makes sense. No obligation.
- A plain-English view of where your evidence stands
- The questions worth asking your suppliers first
- A scoped pilot proposal, only if it makes sense
30 minutes · No obligation · No drawings or controlled data needed
Prefer email? info@lodeline.org
Prefer to talk? Call Yash Sharma at (602) 315-9861
Not ready to book? Tell us about your parts first (about 4 minutes)