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.
1 January 2027 Mining, refining and separation come into scope
30 minutes · No obligation · No drawings or controlled data needed
/ What we do
Your supplier evidence,
organized 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
For contracts awarded from 1 January 2027, the restriction reaches mining, refining and separation, not only melting and production. See sources.
/ The rule
What the clause
looks at.
Three points decide whether the clause reaches your parts.
- What it 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.
- When each stage counts.Today: material melted or produced in those countries.Since July 2026: DoD class deviation 2026-O0041 carries the rule in new solicitations and contracts with clause 252.225-7961.Contracts awarded on or after 1 January 2027: also material mined, refined or separated there, under the National Defense Authorization Act for Fiscal Year 2026 (December 2025).
- What contractors should check. Contracts that already include the May 2024 clause keep their own wording, so check which clause your contract carries and when it was awarded. The clauses include exceptions, and contractors are expected to include them 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.
Request a strategy meeting
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 that may 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.
Request a strategy meeting
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 and are never saved or added to the address bar. They are sent only if you choose to email yourself the result.
/ 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.
/ About Us
Meet the founders.
You work with us directly.
Lodeline is run by its two founders, and your strategy meeting is with one of us.
Dylan Wang
Co-founder
United States / TaiwanDylan turns a complex rule into questions suppliers can actually answer. As a management consulting analyst on Accenture's ASIS Life Sciences team, he broke down operational problems in a heavily regulated industry into structured analysis and clear recommendations, the core of a DFARS 252.225-7052 review. As co-founder of ELunity Care, part of StarterStudio's Build Stage program in Orlando, he led in-person customer discovery with skilled-nursing and assisted-living leaders across Florida and turned their feedback into a product that drew pilot interest from multiple facilities. At Lodeline he leads client work and regulatory research across the U.S. and Taiwan.
- Former Accenture consulting analyst
- Co-founded ELunity Care
- Barrett, The Honors College
- B.S. Biological Sciences, summa cum laude
Yash Sharma
Co-founder
Greater Phoenix AreaYash, a neuroscience researcher who works across biology, engineering and AI, brings a scientist's standard of proof to supply-chain records. In his research at Barrow Neurological Institute, every result has to trace back to the raw data, and he builds the Python pipelines and quality checks that make that possible. He also manages vendor sourcing, procurement and budgets, so he knows the buyer's side of a supplier relationship. Through VelOpus he builds software with provenance and audit logging designed in. At Lodeline he applies the same standard: every entry in an evidence pack is tied to the document behind it.
- Researcher, Barrow Neurological Institute
- Founder, VelOpus
- Barrett, The Honors College
- Vendor sourcing & procurement
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/ Engagement
Start with a pilot.
Decide from there.
5–7 weeksMostly supplier response time. Gaps still open at the end are marked, not hidden.
Fixed feeAgreed in writing before any work begins, for a scope we set together.
You sendPart numbers, material descriptions and supplier names. No drawings or controlled data.
You receiveA five-section evidence pack: summary, stage records, document register, open questions, limits.
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
- Same evidence-pack format as the pilot
/ Not ready for a meeting?
Get the readiness
checklist.
A short checklist of the questions to answer before a customer asks about DFARS 252.225-7052 or 252.225-7961: 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 strategy meeting 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 rules also look 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.
Our contract says 252.225-7052. Another says 252.225-7961. What is the difference?
Both restrict the same materials from the same covered countries. 252.225-7052 is the long-standing DFARS clause; 252.225-7961 is the version DoD has used in new solicitations and contracts since its July 2026 class deviation. Under the National Defense Authorization Act for Fiscal Year 2026 and clause 7961, the restriction on material mined, refined or separated in a covered country applies to contracts awarded on or after 1 January 2027. Older contracts keep the clause they were awarded with unless they are modified. Check which clause and award date your contract or purchase order shows, and confirm with your contracting officer or the responsible reviewer.
How long does a pilot take?
A typical pilot takes five to seven weeks, depending mostly on suppliers. Scoping and sending requests take about a week. Suppliers then get about three weeks to reply, with reminders on days 3, 7 and 14. Review and the evidence pack take one to two weeks. If replies are late or missing, we still deliver the pack, with those gaps marked open.
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.
- DoD Class Deviation 2026-O0041 (Revision 1), DFARS Part 225, prescribing clause 252.225-7961, Restriction on the Acquisition of Certain Magnets, Tantalum, and Tungsten (June 2026), for new solicitations and contracts. Paragraph (b)(1)(ii): no covered material mined, refined, or separated in a covered country may be delivered under a contract awarded on or after 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. Alternate copy: Cornell LII.
- National Defense Authorization Act for Fiscal Year 2026 (Pub. L. 119-60, December 2025), section 848 (see the amendment notes to 10 U.S.C. 4872): the restriction on material mined, refined or separated in a covered country applies to contracts awarded on or after 1 January 2027.
- Executive Order 14415, 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 19 October 2026. Regulations change; always confirm the clause version and award date in your contract.
/ Get started
Request a
strategy meeting.
Answer five quick questions, then pick a time for a 30-minute strategy meeting. You can add detail about your parts and suppliers afterwards, so the meeting is about your situation.
Emailinfo@lodeline.org
Call Yash Sharma(602) 782-9731
致電 Dylan Wang（王家傑）0975-233-601
LINE 聯絡 Dylan Wang（王家傑）加入 LINE 好友用 LINE 掃描 QR Code，或點此直接開啟 LINE開啟 LINE
Prefer to book straight away?Pick a 30-minute slot
LINE 聯絡 Dylan Wang（王家傑）加入 LINE 好友用 LINE 掃描 QR Code，或點此直接開啟 LINE開啟 LINE
Prefer to book straight away?Pick a 30-minute slot
行事曆由 Calendly 提供，介面僅有英文。預約步驟：① 點選日期（Select a Day）② 點選時間 ③ 按「Next」填寫姓名與電子郵件 ④ 按「Schedule Event」完成預約。時間會自動以您所在地的時區顯示。
The calendar is provided by Calendly and loads only when you choose to see it.
Calendar not loading? Open it in a new tab. Sending the form first helps us prepare, but booking here is fine too.
How we handle your information
We use your answers only to prepare for your meeting and follow up. No drawings or controlled data needed. See our privacy notice.
30 minutes · No obligation · No drawings or controlled data needed
/ Got it
Thanks. Now pick a time.
We'll review your answers before we speak. In the meeting we'll go through which of your parts to look at first, what to ask your suppliers, and whether a scoped, fixed-fee pilot makes sense.
- 30 minutes on Google Meet
- Specific to the parts and suppliers you described
- You leave with the first questions to send your suppliers
After you book, answer 2 minutes of optional questions below the calendar
行事曆由 Calendly 提供，介面僅有英文。預約步驟：① 點選日期（Select a Day）② 點選時間 ③ 按「Next」填寫姓名與電子郵件 ④ 按「Schedule Event」完成預約。時間會自動以您所在地的時區顯示。
Calendar didn't load? Open it in a new tab or email info@lodeline.org.
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