Critical

DPAS Directive Allocation Order and Additional Requirements for Recoverable Critical Minerals and Materials

BIS issues a temporary final rule restricting exports of black mass and tungsten waste/scrap without a license under the DPAS, effective immediately.

Aforeworn detected this change in the International Trade & Tariffs (ITC / CBP / USTR) space on August 6, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Critical. Exporters, recyclers, and traders of black mass (from batteries) and tungsten waste/scrap, including those in the critical minerals supply chain. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Effective immediately (temporary final rule published August 6, 2026).. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors International Trade & Tariffs (ITC / CBP / USTR) 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 license requirement for black mass and tungsten waste/scrap under the Defense Production Act (DPAS) allocation order.

Who it affects

Exporters, recyclers, and traders of black mass (from batteries) and tungsten waste/scrap, including those in the critical minerals supply chain.

What you must do

Obtain a BIS export license before shipping these materials; review current export orders and suspend shipments until licensed.

Deadline

Effective immediately (temporary final rule published August 6, 2026).

Source: https://www.federalregister.gov/documents/2026/08/06/2026-16078/dpas-directive-allocation-order-and-additional-requirements-for-recoverable-critical-minerals-and

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