Executive Order 14415

Can you produce an indentured BOM traced to raw material origin?

On January 1, 2027, routine waivers for covered materials sourced from covered nations end. Failure to qualify an alternate source for exposed material is grounds for suspension or termination of task orders, options, or the underlying contract.

Request a risk assessment See the covered materials

Two clocks running on defense supplier compliance

One date is fixed. The other is a rulemaking already in motion. Both point at the same question about where your materials come from.

The fixed clock

January 1, 2027: the waiver cutoff

On January 1, 2027, routine waiver issuance under 10 U.S.C. 4872(c)(1) for covered materials sourced from China, Russia, North Korea, and Iran ends, and the statutory restriction expands upstream to materials mined, refined, or separated in covered nations.

The clock in motion

Rulemaking arriving as DFARS clauses

The order directs rulemaking, within 180 days, requiring contractors at every tier to map supply chains to the origin of raw materials and to screen suppliers for foreign ownership, control, or influence, arriving as DFARS clauses through 2027.

The covered materials, and where they hide in electronics

Six categories are covered today. Gallium and germanium join December 18, 2027. A covered material rarely names itself on a BOM.

Samarium-cobalt magnets

In motors and sensors.

Neodymium-iron-boron magnets

In motors and sensors.

Tantalum

In capacitors.

Tungsten metal powder

In contacts, counterweights, and heat sinks.

Tungsten heavy alloy

In contacts, counterweights, and heat sinks.

Molybdenum

In power packaging.

Joins December 18, 2027

Gallium

In RF and power semiconductors.

Joins December 18, 2027

Germanium

In IR optics.

The readiness checklist

Six questions to ask before a prime asks them of you.

1 Do you have a complete parts inventory, with manufacturer, part number, description, and vendor where the part is not purchased direct?
2 Can you map each part to the origin of its materials?
3 Do you know where covered materials appear anywhere, at any tier?
4 Do you know where you have covered-nation exposure?
5 Where exposure exists, do you have a path out, an alternate source or a design-out?
6 Could you produce an indentured BOM on demand, in days?

The risk assessment

Email us with your product and we will scope a risk assessment against the EO 14415 covered materials list. No cost, no obligation, no design data.

Request a risk assessment

Regulatory Radar

We cover the DFARS rulemaking the week the implementing clause publishes. Ask to be added and the brief lands in your inbox.