DFARS questions start with the contract

Identify the rule being asked about

The National Defense Authorization Act is legislation; DFARS contains acquisition rules and contract clauses. Neither expression, used alone, defines the assurance a particular magnet order requires. Ask which clause, version, deviation and contractual flow-down apply.

This page addresses the interpretation of documentation requests. It does not determine eligibility for an award, approve an application or provide an assurance for a particular delivery. Where the contract wording is unclear, the contracting party needs an authoritative interpretation before relying on a supplier statement.

Read the current version

The published DFARS 252.225-7052 clause covers specified materials including NdFeB and SmCo magnets. Its covered-country definition includes China, Russia, Iran and North Korea. It contains conditions, exceptions and subcontract provisions; it is not a general prohibition on all commercial magnet trade.

The DoD class-deviation register includes a 2026 revision affecting Part 225. That means the older clause's date language must not be repeated as a universal rule for every 2027 delivery. The exact effect of the applicable deviation, transition and award date requires current contract review. This guide deliberately does not declare that question settled for your order.

Match the statement to its evidence

A material-origin requirement can concern upstream processing as well as the country where a finished magnet was manufactured. Final machining or shipment from another country does not, by itself, establish the earlier production history.

Before requesting a declaration, define the material, relevant production stages, named facilities where required, covered lots and evidence acceptable under the contract. A technical datasheet, dimensional report and customs-origin document have different purposes. Their combined presence does not automatically prove the contractual origin requirement.

Our origin and traceability guide provides a way to separate those questions. Any unavailable evidence should be disclosed as a gap, not converted into an unqualified compliance statement.

Keep different restrictions separate

A buyer's country preference, a DFARS contract provision, customs origin and an export licence are different subjects. One document is unlikely to settle all of them. Legal review may also need to consider other requirements beyond the magnet clause; this page is not an exhaustive compliance determination.

For EMTXI, the practical starting point is the requested wording and the evidence actually obtainable for a proposed route. We can discuss the documentation enquiry, but do not promise compliant availability, an exception, or a certification before the requirement and evidence have been reviewed.

Documentation questions