Defense Supply Chain Compliance: Critical Minerals Waiver Cessation Takes Effect January 1, 2027
Orrick Herrington & Sutcliffe – On July 20, 2026, President Trump signed Executive Order 14415, “Securing America’s Defense Supply Chains and Ensuring Domestic Acquisition of Critical Materials.” The order directs the Secretary of War and the Secretaries of the military departments to cease issuing waivers under 10 U.S.C. § 4872(c)(1) for the acquisition of covered materials from covered countries, effective January 1, 2027. This means that defense contractors who currently rely on waivers to source specialty metals, tungsten, rare earth elements, and other covered materials from China, Russia, North Korea, or Iran, including through Tier 2 and Tier 3 suppliers, will lose that pathway in fewer than 100 days.
