You can’t de-risk a material you can’t find

On 10 November 2026, China’s pause on its rare earth export controls runs out. On 1 January 2027, US defence contracts stop accepting rare earth magnets mined or processed in China, at any stage of the supply chain.

Now ask most manufacturers a simple question. Which critical raw materials are in our products? How much? In which parts? From which suppliers?

The honest answer is usually: we’re not sure.

That is the real exposure. The regulations are not the problem. The blind spot underneath them is.

The dates that matter

Already in force: under the EU Critical Raw Materials Act, large companies making strategic technologies must assess their raw material supply chains at least every three years. These technologies include batteries, motors, aircraft and robotics.

UK firms: there’s no CRMA equivalent here yet. That isn’t breathing room. Your EU and US customers will pass their obligations straight down to you.

• 10 Nov 2026: China’s pause on its rare earth export controls expires. If reinstated, the controls reach finished parts with as little as 0.1% Chinese-origin rare earth content.
• 1 Jan 2027: US defence contracts ban NdFeB and SmCo magnets, tantalum and tungsten if any stage of production, from mine to finished part, happened in China, Russia, Iran or North Korea. On the same day, Executive Order 14415 ends routine waivers.
• Spring 2027: US defence suppliers at every tier will be expected to submit a bill of materials traced back to the raw material.
• 18 Aug 2027: EU battery due diligence on cobalt, lithium, nickel and graphite begins.
• 24 May 2029: EU magnet labelling applies to vehicles and MRI scanners, showing magnet type, location and how to remove it.

Why “act now” isn’t a slogan

Finding the materials is quick if you have the data. Replacing them takes years.

A new magnet grade, alloy or capacitor chemistry means redesign, testing and requalification. After 1 January, a waiver requires a mitigation plan with a substitution path and a removal timeline. You need that path before January, not after.

Each industry feels it differently

• Aerospace has the long requalification cycles, and the waiver safety net is going.
• Automotive has magnets in dozens of small motors nobody lists.
• Medical devices can’t change a material without significant regulatory review.
• Industrial manufacturers buy most of their exposure inside sub-assemblies.

Different symptoms, same root cause: nobody has a complete picture of what’s in the product.

Every regulation assumes you know what’s in your products

The US ban assumes you know where your magnets are. The executive order assumes you can build a fully traced BOM. The EU’s risk assessments and labelling rules assume you know which materials you use and where.

Most manufacturers don’t. Critical raw materials rarely appear in the BOM. They sit in the parts inside the parts: the tantalum capacitor on a bought-in circuit board, the magnet in a sensor, the cobalt in a bearing.

Supplier surveys won’t close that gap by January. Response rates are poor, answers are inconsistent, and suppliers several tiers down often don’t know either.

This is what Viridium AI does. We take your BOM and show you:

• Which critical raw materials are in each product, across the full EU and US lists
• How much, at part and product level
• Where they’re hidden, down to the purchased component
• Which suppliers they come from, so you know who to ask and where tracing has to start
• What could replace them, with AI-predicted alternative materials, so substitution work starts before the deadline does

We don’t trace country of origin. We give you what has to come first: you can’t trace, substitute or report a material you haven’t found.

Start with the question you can’t answer yet

Before January, every manufacturer selling into US defence, the EU market or both should be able to say which products contain critical raw materials, how much, in which parts, from which suppliers, and where an alternative exists.

If you can’t answer that today, that’s your first compliance gap.