DFARS & NDAA Compliance

By Dennis Blacksmith The space industry is often viewed as separate from traditional defense programs, but the new DFARS 252.225-7052 and NDAA §842 requirements will have a significant impact on many space companies. Modern satellites, launch vehicles, and ground systems increasingly rely on commercial off-the-shelf components — including electronics, power systems, and actuators that contain critical materials such as neodymium magnets, tantalum capacitors, tungsten, and adv

By Dennis Blacksmith One of the lesser-known complexities of the new DFARS 252.225-7052 rules involves dopants used in rare earth magnets. Dopants are small amounts of additional elements intentionally added during the manufacturing process to enhance the performance of neodymium-iron-boron and samarium-cobalt magnets. Common dopants include dysprosium, terbium, praseodymium, and other rare earth elements. These additives are critical for improving temperature resistance, mag

By Dennis Blacksmith In today’s defense and aerospace environment, compliance with DFARS 252.225-7052, NDAA Section 5949, and trusted parts requirements is essential. But true security goes deeper than paperwork. It depends on the people and organizations behind the processes. When selecting partners for supply chain compliance, attestation, risk assessments, or COTS/end-item integration, organizations must ask a critical question: Do the people I’m trusting with these sensit

By Dennis Blacksmith One of the most important — and often misunderstood — aspects of the new DFARS 252.225-7052 rules is how integration affects commercial off-the-shelf (COTS) components. Many companies assume that if the hardware is COTS, it remains exempt from the new tracing requirements. The reality is more nuanced. When you take commercial hardware — such as computers, displays, VR headsets, tablets, or edge devices — and combine it with purpose-built training software

By Dennis Blacksmith Samarium-cobalt magnets are one of the two types of rare earth magnets specifically covered by the new DFARS 252.225-7052 requirements taking effect in 2027. These high-temperature, high-performance magnets are essential in many defense applications where reliability under extreme conditions is critical. Unlike neodymium magnets, samarium-cobalt magnets maintain their magnetic properties at much higher temperatures, making them ideal for aerospace, naval,

By Dennis Blacksmith Neodymium-iron-boron magnets are among the most critical materials affected by the new DFARS 252.225-7052 requirements, and they present one of the clearest examples of supply chain vulnerability. China currently dominates global production of neodymium-iron-boron magnets, controlling approximately 80-90% of the world’s supply. This heavy reliance on a single country creates significant national security and supply chain risks for the United States. These

By Dennis Blacksmith As the new DFARS 252.225-7052 and NDAA §842 requirements take effect, prime contractors are increasingly flowing these obligations down to their subcontractors and suppliers. This creates a complex web of compliance requirements throughout the supply chain that can be difficult to manage consistently. For primes, overseeing this flow-down process often becomes challenging when each subcontractor responds differently, with varying levels of detail, documen

By Dennis Blacksmith In the defense industry, trust is not just important — it is foundational. When dealing with complex compliance requirements like the new DFARS 252.225-7052 and NDAA §842 rules, companies need partners they can rely on to provide accurate, defensible, and practical solutions. At RavenClear, we believe trust is built through three key elements. First, deep expertise. Our work is grounded in real operational experience from naval aviation and program manage

By Dennis Blacksmith Principal, RavenClear – a division of Ravenswake Global Former Naval Aviator and NAWCTSD Program Manager The new DFARS 252.225-7052 and NDAA §842 rules are just the beginning. While current requirements focus on magnets, tantalum, tungsten, and advanced batteries, the U.S. government is clearly moving toward broader control over critical materials supply chains. The strategic goal is to reduce dependence on adversarial nations for materials essential to n

By Dennis Blacksmith Tantalum is one of the most critical materials affected by the new DFARS 252.225-7052 requirements, yet many companies don’t realize how extensively it’s used in their products. Tantalum is prized for its ability to store electrical charge efficiently and resist corrosion. You’ll find it in capacitors — the most common use — with almost every electronic circuit board in modern systems containing tantalum capacitors. It also appears in high-performance ele

By Dennis Blacksmith The new DFARS 252.225-7052 and NDAA Section 842 supply chain requirements are creating a clear divide in the defense industry. Companies that prepare now are gaining a meaningful competitive advantage, while those that wait are exposing themselves to increasing risk. How Early Preparation Creates Advantage Companies that start assessing their supply chain exposure early can include compliance costs as line items in their proposals. This leads to more accu

By Dennis Blacksmith Many defense contractors underestimate the practical consequences of the new DFARS 252.225-7052 and NDAA Section 842 supply chain requirements. The risks go far beyond paperwork. Real-World Consequences of Non-Compliance Companies that fail to properly address these rules face several serious risks: Delayed system acceptance is one of the most common outcomes. Contracting officers increasingly require clear documentation of supply chain compliance before

By Dennis Blacksmith The updated DFARS 252.225-7052 and NDAA Section 842 requirements are more than just regulatory changes. They represent a strategic effort to reduce America's dependence on covered countries for critical materials. The National Security Challenge For years, the U.S. has relied heavily on China, Russia, and other covered countries for rare earth magnets, tantalum, tungsten, and advanced battery components. This dependence creates vulnerability in our defens

By Dennis Blacksmith The updated DFARS 252.225-7052 and NDAA Section 842 requirements will impact far more than just training and simulation systems. These rules apply across the entire defense industrial base. Industries Most Affected Several sectors face significant compliance challenges as the 2027 deadline approaches: Training and Simulation Systems Companies developing simulators, VR/AR platforms, and instructor stations often integrate commercial hardware with proprieta

By Dennis Blacksmith The DFARS 252.225-7052 regulation includes a specific electronic device exception. Many companies interpret this broadly, assuming any electronic component automatically qualifies for protection. The reality is more nuanced. The exception is primarily intended to cover standalone commercial electronics used in administrative, general support, or test roles. It is not designed to protect components once they are integrated into a larger defense end item. W

By Dennis Blacksmith One of the most dangerous misconceptions in defense supply chain compliance is the assumption that commercial off-the-shelf (COTS) items remain exempt from the new rules. The updated DFARS 252.225-7052 and NDAA Section 842 requirements are changing that reality. The regulation is clear that COTS items lose their exception once they are incorporated into a defense end item. This includes training simulators, VR/AR systems, instructor stations, and any othe

By Dennis Blacksmith Defense contractors are about to face one of the most significant supply chain compliance shifts in years. The updated DFARS 252.225-7052 and NDAA Section 842 rules will take full effect in 2027, bringing major changes to how companies must trace critical materials. These requirements significantly expand traceability for neodymium-iron-boron and samarium-cobalt magnets, tantalum, tungsten, and advanced batteries — with the focus now extending upstream to