# DoD Expands Covered Materials Restrictions

The Department of Defense’s DFARS covered-materials rules are set to expand on January 1, 2027, restricting delivery of covered materials linked to mining, refining, or separation in China, Russia, North Korea, or Iran. DFARS 252.225-7961 (June 2026) ties the expanded restriction to the contract award date, but does not automatically replace DFARS 252.225-7052 (May 2024) in existing contracts. With the effective date roughly 70 days away, contractors should identify affected deliveries and contract instruments and obtain express written amendments before delivery rather than assume a clause swap provides a safe harbor.

- Review contracts and planned deliveries for covered materials and identify which clause applies based on each contract’s award date.
- Where an existing contract needs a clause change, seek express written agreement from the contracting officer before delivering affected materials.
- Validate supply-chain provenance and strengthen subcontract controls for upstream mining, refining, and separation sources; the clause change alone does not eliminate sourcing risk.

**Jurisdictions:** federal
**Industries:** Defense & Military
**Topics:** Regulatory Compliance
**Published:** October 22, 2026

### Government Entities
- U.S. Department of Defense (DoD)

### Vendors
- Pillsbury Winthrop Shaw Pittman LLP (Legal adviser)

### Sources
- [Time Is Running Short to Update DFARS Covered Materials Clauses | Pillsbury Winthrop Shaw Pittman LLP - JDSupra](https://www.jdsupra.com/legalnews/time-is-running-short-to-update-dfars-5921630) - JD Supra
- [DFARS Clause Swap China Rare Earths Compliance Risk](https://rareearthexchanges.com/news/dfars-china-rare-earths-compliance-risk) - Rare Earth Exchanges