US DFARS Case 2020-D007: restriction on DoD acquisition of tantalum from North Korea, China, Russia and Iran

Mechanism

Section 849 of the FY2020 NDAA directed DoD to restrict acquisition of tantalum sourced from covered adversary nations, following the same statutory pattern DoD has previously used for other specialty metals (e.g. tungsten, certain magnet materials — see the related DFARS rules referenced in downstream trade-press coverage of this rule). DFARS Case 2020-D007 implements that mandate: DoD contracting officers may not acquire tantalum metal or alloys "melted or produced" in North Korea, China, Russia or Iran, nor any end item manufactured in one of those countries that contains covered tantalum, absent an applicable exception. The rule took effect immediately on publication (25 August 2022) rather than after a standard delayed-effective-date period, consistent with other statutorily-mandated DFARS specialty-metals restrictions.

Downstream implications

• Defense-supply-chain tantalum sourcing (capacitors, superalloys,

cutting tools) must be certified as non-Russian/Chinese/Iranian/ North Korean origin for any DoD contract, pushing DoD suppliers toward tantalum from DRC, Rwanda, Brazil, Australia and conflict-free smelters already qualified under existing 3TG/dodd-frank-adjacent compliance programs.

• Part of a broader post-2020 pattern of DFARS specialty-metals

restrictions (tungsten, rare-earth magnets) narrowing DoD's supplier base away from the four named countries one material at a time.

Open questions

• The specific DFARS clause number added to the regulation text and

any carve-outs/exceptions (e.g. for below-threshold purchases or commercial-item acquisitions) were not independently confirmed from the primary Federal Register text during filing — federalregister.gov served a bot-verification redirect rather than the document body.

• Compliance/enforcement data (contracts rejected, waivers granted)

since 2022 was not sourced.