BIS Imposes Critical Minerals Export Restrictions on Black Mass and Tungsten Waste and Scrap - Holland & Knight
BIS has imposed export restrictions on critical minerals, specifically black mass and tungsten waste and scrap, affecting exporters in the defense, aerospace, semiconductor, and freight forwarding sectors.
Aforeworn detected this change in the Export Controls & ITAR (DDTC / BIS / DFARS) space on August 14, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. Defense manufacturers, aerospace/dual-use exporters, semiconductor & tech exporters, freight forwarders/brokers dealing with critical minerals. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Not specified in the provided text.. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Export Controls & ITAR (DDTC / BIS / DFARS) continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
New export restrictions on black mass and tungsten waste and scrap under BIS regulations.
Who it affects
Defense manufacturers, aerospace/dual-use exporters, semiconductor & tech exporters, freight forwarders/brokers dealing with critical minerals.
What you must do
Review current export transactions involving these materials to determine if a license is now required; apply for licenses as necessary.
Deadline
Not specified in the provided text.
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