Army Expects Only Minor Disruptions From Upcoming Critical Mineral Ban

WASHINGTON — With the deadline for defense contractors to eliminate critical minerals sourced from rival nations fast approaching, the Army predicts it will experience only limited effects on firms still working to meet the requirement, according to an Army official.

Executive Order 14415, issued in July, sets a January 2027 cutoff for U.S. firms to cease using critical materials and minerals sourced from China, Russia, Iran, and North Korea. A waiver may be granted only after the government approves a mitigation plan that details concrete actions the company is taking to secure alternative suppliers domestically or from allied nations.

Liz Miranda, executive deputy to the commanding general at Army Materiel Command, noted on Wednesday that requiring companies to trace their supply chains to the raw‑material level is far from simple.

“We’re making progress, but we’re not there yet. Consequently, we expect to observe some impact when the deadline arrives in January,” she told attendees at the Association of the U.S. Army conference.

When asked by Breaking Defense about the potential impacts, Miranda said she does not foresee any catastrophic “off‑the‑cliff” scenarios for the service.

Instead, she explained, “I envision a gradual process in which everyone is held accountable for addressing the risks we know exist due to our reliance on foreign adversaries.”

The order covers critical minerals such as tungsten alloys—used in engine parts and hypersonic systems—and germanium, employed in thermal imaging. A September report by the Aerospace Industries Association notes that China dominates global production of both materials.

Miranda highlighted the Army’s recent announcement of a upcoming “manufacturing rodeo” designed to uncover supply‑chain and manufacturing risks that the service may have overlooked.

“Unfortunately, we cannot bring every required component in‑house, especially those needed for drone dominance,” she said. “Through this rodeo, we aim to examine U.S. domestic capabilities, identify gaps, and then collaborate with industry to invest in building domestic capacity or partner with allies to secure resources that can be scaled to meet our needs.”

In a July interview, Michael Cadenazzi, Assistant Secretary of Defense for Industrial Base Policy, told Breaking Defense that the Pentagon is prepared to assist companies seeking waivers, provided they demonstrate a good‑faith effort to locate alternative sources of supply.

“We need to tell companies, ‘Show us how you will address this issue via friend‑shoring, domestic sourcing, or supplier changes,’” he said. “If a legitimate gap exists and you have a plan requiring a time window to bridge it, that is exactly what we need to know.”

Nevertheless, defense trade groups have warned that the timeline is too aggressive. The Aerospace Industries Association contends that waivers will likely remain needed for years beyond the January 2027 deadline because domestic supplies of critical minerals are currently inadequate to satisfy industry demand.

The September AIA report found that “significant domestic processing, refining, and magnet production capacity for aerospace‑grade materials will not be available until 2028 or later,” noting that further certification and qualification steps could delay availability even more.

These challenges are intensified by the order, as waivers will be granted only to companies whose mitigation plans receive government approval, yet the agency provides minimal guidance on what qualifies as an acceptable plan, according to Dak Hardwick, AIA Vice President of International Affairs.

“Industry continues to seek clarity on the mitigation‑plan standards and processing timelines,” he said on Tuesday. “The AIA is urging industry, government, Congress, and mineral producers to collaborate on a pragmatic path forward that meets the sector’s unique needs, maintains waivers where qualified domestic supply is lacking, and prevents disruptions to defense production.”

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