Executive Order 14415, released in July 2026, requires U.S. defense contractors to stop sourcing critical minerals from adversary nations by January 2027. The Army expects supply chain disruptions as domestic aerospace-grade material production remains insufficient until 2028 or later.
What's happening
- Companies must submit mitigation plans for government approval to obtain waivers past the January 2027 deadline.
- Critical minerals covered include tungsten alloys used in engine components and hypersonics, and germanium used in thermal imaging systems, with China dominating both markets.
- The Army will conduct a manufacturing rodeo to identify domestic supply gaps and assess which parts cannot be insourced, particularly for drone programs.
- Industry lacks clarity on what constitutes an acceptable mitigation plan and the government's approval timeline.
Why it matters
- Insufficient domestic processing and refining capacity until 2028 or later creates production risk for hypersonics, thermal imaging, and drone systems through 2027.
- Waiver restrictions tied to approved mitigation plans may force contractors to invest in new suppliers or friendshoring arrangements on accelerated timelines.
- Supply chain mapping down to raw material level, required by the order, exposes operational complexity that many contractors have not fully assessed.
Going deeper
- The Pentagon indicated willingness to grant time-limited waivers for companies with legitimate gaps and concrete mitigation plans, but specific criteria remain undefined.
- The Aerospace Industries Association argues waivers will be necessary for years after January 2027 as certification and qualification of domestic materials extend timelines beyond 2028.
The intrigue
- The disconnect between the January 2027 compliance deadline and domestic capacity arrival in 2028 or later creates a one-to-two-year period where either waivers must remain in place or production faces deliberate slowdown to preserve security classification.
- Government approval standards for mitigation plans are undisclosed, leaving contractors unable to validate plans before submission.
The fine print
- Waivers require government-approved mitigation plans with no published standard for approval, timeline for government feedback, or clarity on waiver duration.
- Certification and qualification activities for domestic aerospace-grade materials may extend availability dates beyond 2028.




