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DFARS 252.225-7052 stops defense contractors from delivering tungsten metal powder or tungsten heavy alloy that traces back to China, Russia, Iran, or North Korea. Today the test is narrow: where the material was melted or produced. On January 1, 2027 it widens to cover the whole chain from the mine forward, and recycled feedstock is explicitly written in.
If you buy tungsten for a defense program, that one change is the thing to plan around. A supplier who satisfies the rule today can fall out of scope in January without changing anything about how they operate.
What the Clause Actually Covers
The full title is “Restriction on the Acquisition of Certain Magnets, Tantalum, and Tungsten,” and the current version carries a May 2024 date. It applies to contracts above the simplified acquisition threshold. Five materials are covered, and the tungsten entries are more specific than most people assume.
| Covered material |
|---|
| Samarium-cobalt magnets |
| Neodymium-iron-boron magnets |
| Tantalum metals and alloys |
| Tungsten metal powder |
| Tungsten heavy alloy, and any finished or semi-finished component containing tungsten heavy alloy |
Read that list closely. It names tungsten metal powder, and it names tungsten heavy alloy along with parts machined from it. Whether a particular item on your drawing sits inside those categories is worth confirming rather than assuming, because the answer drives everything downstream.
Which Countries Are Covered
Four, and the list has not moved:
- The People’s Republic of China
- The Russian Federation
- The Islamic Republic of Iran
- The Democratic People’s Republic of North Korea
What Changes on January 1, 2027
The entire shift fits in one comparison.
| Through December 31, 2026 | From January 1, 2027 | |
|---|---|---|
| Restricted steps | Melted or produced | Mined, refined, separated, melted, or produced |
| Practical reach | The melt and downstream | The full chain, starting at the ore |
The regulation states it plainly. Through the end of 2026:
“Effective through December 31, 2026, the Contractor shall not deliver under this contract any covered material melted or produced in any covered country, or any end item, manufactured in any covered country, that contains a covered material.”
And from the start of 2027:
“Effective January 1, 2027, the Contractor shall not deliver under this contract any covered material mined, refined, separated, melted, or produced in any covered country, or any end item, manufactured in any covered country, that contains a covered material.”
Five verbs where there were two. Every step upstream of the melt now counts, which is where most tungsten supply chains have their exposure.
For Tungsten, the Chain Starts at the Ore
The clause does not leave the tungsten scope to interpretation. It writes the chain out:
“For production of tungsten metal powder, tungsten heavy alloy, or any finished or semi-finished component containing tungsten heavy alloy, this restriction includes mining or production of a tungsten ore or feedstock, including recycled material, through production of tungsten metal powders, tungsten heavy alloy, or any finished or semi-finished component containing tungsten heavy alloy.”
Two phrases in there carry most of the weight. The chain begins at “mining or production of a tungsten ore or feedstock,” which is as far upstream as it goes. And then there is the parenthetical almost everyone misses.
Recycled Tungsten Does Not Reset the Origin
Reclaimed tungsten is a real and useful input. Scrap carbide, turnings, and reclaimed heavy alloy all get fed back into powder production, and the economics are good. There is a common assumption that recycled material launders origin, because the scrap was collected domestically and the atoms have been through a furnace since they left the mine.
The clause closes that door for tungsten. The phrase “including recycled material” sits directly inside the sentence defining the restricted chain. If the feedstock originated in a covered country, running it through a recycling stream does not make it compliant from 2027 onward. Any supplier leaning on reclaimed input as their domestic story should be asked where that scrap came from originally.
252.225-7052 Is Not 252.225-7009
These two clauses get treated as interchangeable and they are not. Certifying to one says nothing about the other.
| 252.225-7052 | 252.225-7009 | |
|---|---|---|
| Title | Restriction on the Acquisition of Certain Magnets, Tantalum, and Tungsten | Restriction on Acquisition of Certain Articles Containing Specialty Metals |
| How tungsten appears | As a product in its own right: tungsten metal powder, tungsten heavy alloy, and components made from it | Only as an alloying element in steel, above 0.25 percent |
| Test applied | Country of origin across the restricted chain | Melted or produced in the United States or a qualifying country |
The distinction matters commercially. A tungsten heavy alloy counterweight is not steel, so 7009’s specialty-metal definition does not reach it as a product. 7052 does. A supplier who answers a 7052 question by pointing at a 7009 certification has not answered it.
The Exceptions Are Narrow and Worth Reading
The clause carves out several situations, including commercially available off-the-shelf items within limits, electronic devices unless otherwise specified, neodymium-iron-boron magnets made from material recycled and processed in the United States, and cases where an authorized agency official has issued a nonavailability determination. There is also a provision effective January 1, 2027 covering a covered material in mill product form that has not been incorporated into an end item.
Whether any of these apply to a given buy depends on the contract and the item, not on the material alone. That is a question for your contracting officer, and it is better asked early than discovered at delivery.
What to Do Before January 2027
- Identify which of your parts contain tungsten metal powder or tungsten heavy alloy, since those are the categories the clause names.
- Ask each supplier where the ore or feedstock originated, not just where the material was melted. Before 2027 those can be different answers. After, only one of them matters.
- Ask specifically about recycled content and its original source.
- Confirm whether your contract carries 252.225-7052, 252.225-7009, or both, and stop treating them as one requirement.
- Get the sourcing position in writing per program and per part rather than as a blanket statement.
Where Tungsten Parts Wyoming Fits
We manufacture tungsten powder-to-part in Laramie, Wyoming, and confirm DFARS 252.225-7052 sourcing on a per-program, per-part basis rather than as a blanket claim. If you are reviewing a bill of materials against the 2027 change, the practical starting points are our tungsten heavy alloy grades, our tungsten powder and raw materials, and the certified property data behind them.
The same sourcing questions apply to consumable tooling on the shop floor, which is worth raising with whoever supplies your depot and MRO tooling programs.
Sources for the clause language quoted above: Acquisition.gov and the eCFR. This article explains a regulation and is not legal advice.
Frequently Asked Questions
What does DFARS 252.225-7052 restrict?
It prohibits contractors from delivering covered materials, including tungsten metal powder and tungsten heavy alloy, that originate in China, Russia, Iran, or North Korea. It applies to contracts above the simplified acquisition threshold.
What changes on January 1, 2027?
The restricted chain expands from material melted or produced in a covered country to material mined, refined, separated, melted, or produced there. For tungsten, the chain explicitly starts at mining or production of the ore or feedstock.
Does recycled tungsten avoid the restriction?
No. The clause includes recycled material within the restricted chain for tungsten, so reclaimed feedstock that originated in a covered country does not become compliant by being recycled.
Is DFARS 252.225-7052 the same as 252.225-7009?
No. 7009 covers specialty metals and reaches tungsten only as an alloying element in steel above 0.25 percent. 7052 covers tungsten metal powder and tungsten heavy alloy as products. A certification to one does not satisfy the other.
Which countries are covered by DFARS 252.225-7052?
China, Russia, Iran, and North Korea.
