RAVENCLEAR
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Defense Industry Rare Earth & Advanced Battery Compliance Assurance
U.S. Department of War rules governing the use of rare earth magnets, tantalum, tungsten, and advanced batteries have changed. Unless fully prepared, significant risk of non-compliance, contract delays and audit exposure exists
Starting January 1, 2027
Full supply-chain traceability for rare earth magnets (NdFeB and SmCo), tantalum, and tungsten used in U.S. Department of War applications becomes mandatory under DFARS 252.225-7052 starting January 1, 2027. Advanced batteries face phased FEOC restrictions beginning in 2028.
From mine to smelter, refining, sintering, and final component integration — every step in the rare earth mineral and advanced battery supply chain must be fully traced and documented.
Federal regulations prohibit the use of these materials if any part of the supply chain originates from or is processed by a foreign entity of concern.
Existing Contract Impact
Even contracts awarded before 2027 are subject to the new rules if delivery occurs on or after January 1, 2027.
Many contractors and subcontractors may discover significant gaps – especially with hidden batteries in COTS equipment, tantalum capacitors, tungsten heavy alloy components, and complex ownership structures.
If non-compliance is left unaddressed, companies likely face rejected deliveries, withheld payments, stop-work orders, increased audit risk, and lost future business.
RAVENCLEAR exists to help you navigate these upcoming challenges successfully — delivering assurance today and practical mitigation support during the multi-year transition.
The Rules Have Changed
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Don't Forget the Batteries
Compliance Starts January 1, 2028
While the 2027 magnet rules often get the most attention, advanced battery compliance under FY2026 NDAA §842 is equally critical and has its own aggressive timeline:
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New acquisition programs: January 1, 2028
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Standard batteries: January 1, 2029
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Existing programs: January 1, 2031
Unlike magnets, there is no broad COTS exception for most advanced batteries and battery cells once they are integrated into a DoD system. The prohibition extends to functional cell components, technology, and FEOC-linked sourcing — including graphite, lithium refining, and cathode materials.
Embedded “black-box” batteries in UPS units, laptops, controllers, and other equipment are a frequent compliance trap. RAVENCLEAR has a dedicated process to identify, trace, and mitigate battery-related risks.
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RAVENCLEAR
Independent Compliance Assurance
RAVENCLEAR is an independent compliance assurance and mitigation service from Ravenswake Global.
We provide independent verification and assurance that your supply chain for rare earth magnets, tantalum, tungsten, and advanced batteries meets the strict requirements of DFARS 252.225-7052 and FY2026 NDAA §842.
When full immediate compliance is not feasible, we prepare comprehensive Waiver Support Packages to support formal National Security and Non-Availability waiver requests submitted by the client to the contracting officer. These packages include detailed risk assessments, market research, transition plans, and sourcing improvement roadmaps.
Built on more than 40 years of naval aviation, operations, program management, and direct support to the Naval Air Warfare Center Training Systems Division (NAWCTSD), we deliver clear, actionable solutions that primes and DCAA auditors respect.
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Our Solution
We Move Business Forward
Meeting compliance requirements shouldn't slow business or overburden teams.
RAVENCLEAR takes full ownership of the complex work required to achieve and maintain compliance to satisfy DFARS 252.225-7052 and FY2028 NDAA §842.
Using our structured execution protocol, we perform supplier outreach, provenance mapping, risk assessment, COTS analysis, tantalum and tungsten screening, battery black-box investigation, and Entity Ownership & Control Review. We then deliver a signed, independent compliance assurance package with official seal and unique verification ID.
This includes preparing comprehensive Waiver Support Packages to support formal National Security and Non-Availability waiver requests. These packages include detailed risk assessments, market research showing lack of alternatives, credible phased transition plans, and collaboration with mines and friendly producers on long-term sourcing improvement roadmaps.
Our goal is to help you maintain profitable operations while meeting regulatory requirements during the industry’s multi-year supply chain transition.
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What You Receive
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Signed RAVENCLEAR Compliance Assurance Letter with official seal and unique ID
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Executive Summary Report with risk assessment and resolution recommendations
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Provenance Disclosure Forms and Reasonable Inquiry Log
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Waiver Support Package (if applicable)
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Online verification link for your prime or contracting officer
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Optional Add-ons
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On-Site Verification at smelters or processing facilities
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Enhanced Entity Ownership & Control Review for FEOC compliance
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Early-Stage Battery Compliance Screening (proactive during proposal or design phase)
RAVENCLEAR helps reduce risk across your supply base while supporting faster, smoother program execution.
Whether you use our service directly or recommend us to your subcontractors, you benefit from consistent, high-quality compliance assurance packages and practical waiver / transition support that strengthens audit defense and program performance.
We’d welcome the opportunity to discuss how we can support your programs.
Contact Us About Prime Partnership
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Frequently Asked Questions
What is RAVENCLEAR ?
RAVENCLEAR is an independent compliance assurance and mitigation service from Ravenswake Global. We specialize in full-execution compliance for rare earth magnets, tantalum, tungsten, and advanced batteries under DFARS 252.225-7052 and FY2026 NDAA §842.
Contract awarded before 2027 but delivery scheduled for 2027 or later, do the new rules apply?
Yes. The restrictions are triggered by the date of delivery, not the contract award date. Many long-lead contracts awarded in 2025 or 2026 will still be subject to the full 2027 traceability requirements if delivery occurs on or after January 1, 2027.
What happens if full compliance isn’t possible right away?
The regulations include provisions for National Security and Non-Availability waivers when compliant material is not reasonably available. RAVENCLEAR prepares comprehensive Waiver Support Packages — including detailed risk assessments, market research, and transition plans — that significantly strengthen your formal waiver request to the contracting officer.
Is RAVENCLEAR just another expense?
No — compliance with these regulations is a contractual obligation. The cost is a legitimate and recoverable contract expense, similar to cybersecurity or quality requirements. RAVENCLEAR helps you meet these requirements efficiently and defensibly.
Do you offer retainers or updated assurance?
Yes. Defense contracts often span multiple years, and supply chains can change. We offer quarterly or annual retainers that include ongoing monitoring, supplier re-verification, and updated assurance as needed.
What if my BOM contains batteries or “black box” items?
We have a dedicated process for battery-laden components. This often includes cell-level inquiry and Entity Ownership & Control Review.
Do you offer on-site verification?
Yes. For high-risk components or when your prime requires stronger assurance, we can conduct on-site visits as a premium add-on.
How much does it cost?
Our pricing is based on the complexity of your BOM — specifically the mix and volume of restricted materials, the number of black-box or embedded items, and overall program scope.
Because we deliver full execution tracing, risk assessment, and practical mitigation support most clients will find RAVENCLEAR significantly more affordable and effective than building equivalent capabilities in-house or hiring general compliance consultants. These costs are also legitimate contract expenses that can typically be recovered through DoD proposals — similar to cybersecurity or quality system compliance.
How do I get started?
Book a free Discovery Call. Tell us about your program — we’ll handle the rest.
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