The New DFARS Rules and the Space Industry: Why Satellite and Launch Companies Should Be Paying Attention
- Dennis Blacksmith
- 8 hours ago
- 2 min read
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 advanced batteries.
When these components are integrated into a system that supports defense missions — whether communications, reconnaissance, navigation, or dual-use applications — they typically lose their COTS exception and become subject to full supply chain tracing requirements.
This creates real compliance exposure for satellite manufacturers, launch vehicle providers, and companies developing ground systems or user terminals. Even companies that primarily serve commercial markets may find themselves affected if their technology is used in defense-related applications or if they work with government customers.
The space domain is increasingly recognized as a critical part of national security. Ensuring secure supply chains for space systems is becoming a priority for the Department of Defense, which means compliance with DFARS and NDAA rules is no longer optional for companies in this sector.
The challenge is particularly acute for companies working on both commercial and government programs. They must navigate different requirements depending on the end use of their technology, which can create complex compliance scenarios that many are only beginning to address.
At RavenClear, we help space and defense companies understand their exposure to these requirements and develop practical compliance strategies that support both commercial innovation and national security needs.
By taking a proactive approach now, space companies can avoid last-minute disruptions and position themselves as reliable partners in an increasingly regulated environment.
