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A NexGen Materials Initiative
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SUPPLY CHAIN VISIBILITY

FEOC origin materials – even 3 levels deep – create potential supply chain risk.

How do you determine your exposure, and what are your options?

3 tiers audited
Your suppliers, their suppliers, and the refiners and processors behind them.
Jan 1, 2027
Routine waivers for covered materials from China, Russia, North Korea and Iran end.
19 of 20
Strategic minerals where China leads global refining, per the International Energy Agency.
WHAT CHANGED

Executive Order 14415 moved the line from "who sold it to you" to "where it came out of the ground."

01

Map every tier

Prime contractors and subcontractors must submit a bill of materials that traces every component, part, piece of equipment, software and material back to the origin of its raw materials.

02

The easy waiver is gone

"We couldn't find it anywhere but China" no longer works. Continued use of covered material from a restricted country now takes a formal mitigation plan: proof of an exhaustive search, the material's origin and a timeline to move off it.

03

Vet every supplier

Contractors must screen suppliers for foreign ownership or control, financial distress and manufacturing risk, then replace the ones that don't hold up. Getting it wrong puts contracts at risk.

THE VISIBILITY PROBLEM

The deeper you look, the less you can see.

Most contractors know their direct suppliers well. A level down it gets harder. Below that, at the refiners, processors and mines, the picture is opaque at best. That's where critical-material exposure tends to hide, and it's where the new rules now reach.

NexGen works with a technology partner that makes those lower tiers visible.

See how we can help →
  1. TIER 1
    Your direct suppliers
    Contracts, contacts, paperwork. Usually clear.
    CLEAR
  2. TIER 2
    Their suppliers
    Knowable, with effort and cooperation.
    PARTIAL
  3. TIER 3+
    Refiners, processors, mines
    Opaque at best. Often routed through intermediaries.
    OPAQUE
  4. ORIGIN
    Raw-material origin: where the requirement now ends.
Sample supply chain trace for germanium, gallium and tungsten. Components on the left connect through materials, suppliers, processors, refiners and mines to countries of origin. Links are color-coded as verified, corroborated, declared, inferred, conflicted or unknown, and missing processors and refiners are shown as unknown boxes.
SAMPLE TRACE WITH ILLUSTRATIVE COMPANY NAMES · TAP TO ENLARGE
"This is not paperwork. It is battlefield preparation."
PETER NAVARRO, WHITE HOUSE ADVISER, ON THE MAPPING REQUIREMENT
FROM MAPPED TO SECURE

One compliant supplier isn't supply chain security.

A map shows you the risk. Security means acting on it, and having more than one qualified source when a supplier fails or falls out of compliance. Where does your program sit?

STAGE 1

Assess

Working out what's in the bill of materials and who supplies it.

STAGE 2

Illuminate

Some origin data is in hand and being studied.

STAGE 3

Improve

The data is actionable, and sourcing is actively changing.

STAGE 4

Monitor

In good shape, and watching for what changes next.

WHERE NEXGEN FITS

See the whole chain. Then fix the weak links.

NexGen works on both sides of the problem. With a technology partner, we help primes and suppliers see where their materials actually come from. And where the answer is the wrong one, NexGen is building lower-cost, U.S.-based processing routes so the trail ends somewhere you can stand behind.

See the materials we're working on →
  • 01
    Supply chain visibility
    Through our technology partner, map the tiers below your direct suppliers and trace materials back toward their origin.
  • 02
    Domestic processing
    U.S.-based routes for ATO, titanium, iodine and lithium, aimed at the steps where foreign control is highest.
  • 03
    Origin you can document
    Processes designed with traceability in mind, so origin questions have answers.
  • 04
    A second source
    Another qualified option, so a single supplier isn't the whole plan.
CONTACT

Working through the new sourcing rules?

Primes, suppliers and program offices: tell us which materials are on your list, or where your map goes dark, and we'll follow up.

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