DFARS 252.225-7052: A Sourcing Guide for Robotics Teams
DFARS 252.225-7052: A Sourcing Guide for Robotics Teams
We posted a short version of this argument recently: there is a sourcing rule coming for robotics that most robotics people have not read, because it is written about magnets. This is the longer version, for the people who now have to do something about it.
The rule is DFARS 252.225-7052, “Restriction on the Acquisition of Certain Magnets, Tantalum, and Tungsten.” It implements 10 U.S.C. 4872, and it appears in DoD contracts, including contracts for commercial products. If your hardware ends up in something delivered to the Department of Defense, at any tier, this clause is likely somewhere above you in the paper chain. None of what follows is legal advice. It is an engineer’s reading of a published regulation, offered so that you know which questions to bring to your contracts people and your counsel. Read the clause itself; it is short.
What the clause restricts today
The clause covers a specific list of materials: samarium-cobalt magnets, neodymium-iron-boron magnets, tantalum metals and alloys, and tungsten in specified forms. It prohibits delivering end items to DoD that contain covered materials melted or produced in a covered country. The covered countries are China, Iran, North Korea, and Russia.
That current standard, melted or produced, is the version many supplier representations were written against. A magnet sintered outside a covered country could satisfy it even if the elements inside came from one.
What changes on January 1, 2027
The 2024 revision of the clause (DFARS Case 2021-D015) extends the restriction to the whole chain. From January 1, 2027, the prohibition reaches covered material mined, refined, separated, melted, or produced in a covered country. It also prohibits delivering end items manufactured in a covered country that contain a covered material.
Recycled feedstock is worth reading carefully rather than assuming, because the clause does not treat it uniformly. For samarium-cobalt, tantalum and tungsten the 2027 supply chain is defined to run from ore or feedstock “including recycled material.” The neodymium-iron-boron provision is written differently: it runs “from mining of neodymium, iron, and boron through production of finished magnets,” and recycled material shows up instead in the exceptions, where a neodymium-iron-boron magnet made from recycled material is carved out if the milling of that material and the sintering of the final magnet both happen in the United States. If you build with neodymium magnets, that is a sourcing route, not a trap.
For a neodymium magnet, that is the difference between asking where the magnet was made and asking where the neodymium came out of the ground, where it was separated into oxide, where the alloy was made, and where the magnet was sintered and magnetized. Those are usually four different facilities, frequently in different countries, and the answer to the first question tells you almost nothing about the other three.
The clause flows down. Subcontracts for items containing covered material carry the substance of the restriction, including subcontracts for commercial products. Being three tiers away from the prime does not put you outside it.
Why this is a robotics rule
A rule about magnets reads like a materials-desk problem until you count the magnets on a robot.
A brushless motor is a stator, a rotor, and a set of permanent magnets, almost always neodymium-iron-boron in anything that cares about torque density. Every actuated joint on a ground platform has one. So do the pumps, the fans, the gimbal drives, and a fair share of the sensors. A six-degree-of-freedom manipulator is, from the clause’s point of view, at least six regulated magnet assemblies before you get to the wrist.
That has a design consequence, not just a procurement one. Motor selection happens early. It drives gearbox selection, thermal design, structure, and control tuning. A program that learns in 2027 that a motor’s magnets cannot be documented learns it after the design is frozen, and a joint is not a component you swap late. The realistic options at that point are a requalification effort or an exception request, and neither is fast.
The exceptions are real. Read them before panicking
Paragraph (c) of the clause carries exceptions, and they matter. Three of them are the ones a robotics integrator actually lands on.
The first is commercially available off-the-shelf items. A COTS end item containing covered material is outside the clause, but the carve-out has a weight test and the test changes on the same date: through the end of 2026 a COTS item loses the exception at 50 percent or more tungsten by weight, and from January 1, 2027 it loses it at 50 percent or more covered material by weight. Read that as a real narrowing. A COTS part that is comfortably outside today because it is mostly not tungsten can fall inside once the measure becomes covered material generally.
The second is electronic devices, which are excepted unless the contract says otherwise. The third is the neodymium recycled-material route above. Beyond the listed exceptions, an authorized agency official can make a nonavailability determination, which is a finding that compliant material of satisfactory quality and quantity cannot be had in the required form at a reasonable price. For magnets, required form means the form and the properties of the magnet, not a generic grade.
What the exceptions do not remove is the need to know your answer. An exception is something you claim, on the record, with facts behind it. “We never checked” is not an exception. The work of finding out where your magnets come from is the same whether the finding leads to compliance, an exception, or a redesign; the only thing that changes with time is how many options remain when the finding arrives.
What to ask your suppliers, in writing
If you integrate actuators, motors, or anything with a magnet in it, we think the useful supplier question looks like this:
For each permanent magnet in the delivered item: where was the ore mined, where were the rare-earth elements refined and separated, where was the alloy produced, and where was the magnet sintered and finished? Can you provide documentation for each step, and will that documentation remain valid for deliveries after January 1, 2027? If any step runs through a covered country, which exception in paragraph (c) do you believe applies, and on what basis?
Send it early. Most suppliers have never been asked, which is not the same thing as having a bad answer. The chain usually runs three or four tiers deep, and each tier answers on its own schedule. Teams that start asking now will have answers, or redesigns, before the date. Teams that start in 2027 will have discoveries.
A note on why we care
We build integrated smart actuator packages, and the ISAP line exists partly because of rules like this one. When the motor, gearing, sensing, and drive electronics are designed as one sealed unit by one party, the provenance question has one place to land instead of four. We are not asserting anything about anyone’s compliance, including our own suppliers’; provenance is something you document, delivery by delivery, not something you claim in a blog post. What we will say is that we started at the motor on purpose, and 2027 is one of the reasons.
The clause is public, the date is fixed, and the question costs a letter. Ask it now.