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Base rate computed from analyst-asserted responds_to: edges in the reverse direction (target-country → issuer-country) for prior issuer-actions on the same target. Modal type + lag percentiles only — not a model output. Treat as a historical anchor for sizing counter-response scenarios, not a forecast in itself.
DoD's "covered materials" sourcing ban (10 U.S.C. specialty-metals-style framework, administered alongside the existing magnet/tantalum/tungsten restrictions) already prohibited DoD from procuring any covered material — or any end item containing one — that was melted or produced in a "covered nation" (China, Russia, Iran, DPRK). Section 844 of the FY2026 NDAA adds three materials to that list: molybdenum, gallium and germanium. Gallium and germanium are the same two materials China placed under its own export-licensing regime in July 2023 (2023-07-03-china-mofcom-gallium-germanium-export-controls) — this action is the mirror-image downstream response, closing a DoD-procurement channel for the same two inputs China restricted on the export side.
Phase-in is staged:
in a covered nation (i.e. upstream ore/concentrate origin now counts, not just final processing).
than the general 2026/2027 schedule, reflecting the more limited number of qualified non-China supply sources for these two inputs).
Two related provisions ride in the same public law:
contracts, grants, other-transaction agreements, private-sector incentives, third-party investment awards, and anti-market-manipulation subsidies to build domestic capacity in kinetic munitions, microelectronics, machine tools, critical minerals, unmanned vehicles and defense space systems — funded through FY2031.
are owned, sourced, refined or produced by a foreign entity of concern (China, Russia, Iran, North Korea), phased in for new acquisitions from 1 January 2028, standard batteries from 1 January 2029, and existing acquisitions by 30 January 2031.
germanium and molybdenum — three inputs where China holds outsized refining/production share and where China has already demonstrated willingness to use export licensing as leverage (July 2023 gallium/germanium controls; the 2025-10-09 lithium-battery-graphite controls, 2025-10-09-china-mofcom-announcement-58-lithium-battery-graphite-export-controls, show the same playbook extended to battery materials).
suppliers a multi-year window to requalify non-China gallium/germanium sources (small-scale Western/allied producers, e.g. US, Canadian, German and Japanese recyclers and by-product refiners) before the ban bites — a similar cadence to the batteries FEOC rule's 2028-2031 ramp.
procurement-restriction stick: DoD can now use equity-style investment and anti-market- manipulation subsidies to backstop the same critical-mineral processors it is simultaneously requiring its contractors to source from.
policy (see also 2025-12-22-us-dow-lattice-materials-germanium-silicon-optics for a DPA Title III award building exactly the kind of domestic germanium capacity this procurement rule will need).
the currently thin non-China refining base, or whether the 2027 deadline slips administratively.
figures were attached to the section itself; actual appropriations will show up in subsequent DoD budget requests.
program cost growth, and whether any of the four battery-material provisions get amended before their effective dates (as occurred with prior-year specialty-metals compliance deadlines).