# DoW Ends Critical Minerals Waivers

Executive Order 14415 ends routine Department of War waivers for covered materials sourced from covered countries effective January 1, 2027—90 days from October 3, 2026. Prime contractors and subcontractors at every tier will need to identify material origins and transition to compliant sources; firms seeking an exception must obtain acceptance of a mitigation plan documenting the source, exhaustive alternative-sourcing efforts, removal steps, and a firm implementation timeline. Federal financing cited for the supply-chain transition includes critical-minerals funding and an EXIM loan facility.

- Contractors should map covered minerals and battery materials through their supply chains, qualify alternative sources, and prepare the required documentation before the waiver cessation date.
- An exception is not automatic: firms seeking one must provide an accepted mitigation plan with the specified sourcing, alternatives, removal, and timing details.
- Available financing includes $7.5 billion in 2025 funding for defense-related critical-minerals investments, $500 million in DOE funding announced in August 2026 for processing, recycling, and manufacturing, and an EXIM loan of up to $10 billion for Project Vault approved in February 2026.

**Jurisdictions:** federal
**Industries:** Defense & Military
**Topics:** Regulatory Compliance, Grants & Funding
**Published:** October 02, 2026

### Government Entities
- Department of War (DoW)
- U.S. Department of Energy (DOE)
- Export-Import Bank of the United States (EXIM)

### Sources
- [Defense Supply Chain Compliance: Critical Minerals Waiver Cessation Takes Effect January 1, 2027 | Orrick, Herrington & Sutcliffe LLP - JDSupra](https://www.jdsupra.com/legalnews/defense-supply-chain-compliance-3606793) - JDSupra