Molybdenum in 10 U.S.C. 4872(f)(1): what interim contract instructions apply while the DFARS definition is updated?

Public Law 119-60, section 844(a)(1), added molybdenum to the definition of covered material in 10 U.S.C. 4872(f)(1). The DFARS definition in 225.7018-1, the definition in Class Deviation 2026-O0041, Revision 1, and clause 252.225-7961 keep the five-material list without molybdenum. DFARS case 2024-D014 already covers this amendment. One view is that the statutory prohibition applies to DoD acquisitions of molybdenum now. The other is that contract obligations follow the clause list, which does not include molybdenum, until the case is completed.

Consequence

No delivery of molybdenum from a covered nation under a current contract has been established.

Proposed correction

Please clarify what interim contract instructions apply to the statutory restriction on molybdenum while case 2024-D014 is pending.

Jurisdiction

United States — federal

Act

Defense Federal Acquisition Regulation Supplement (48 CFR chapter 2) and Class Deviation 2026-O0041, Revision 1

Place

10 U.S.C. 4872(f)(1); DFARS 225.7018-1; clause 252.225-7961(a)

Record

Question of reading or data

Class

Question of reading or data

Where it arose

The text of the act

Arxo's conclusion

Confirmed

Official text

Unchanged at last check

Last checked

2026-10-29

Evidence

Pair of quotations. Quotations are verbatim from the official material; translations are ours and marked.

tantalum metals and alloys; and (F) molybdenum.

(4) Tungsten metal powder; and (5) Tungsten heavy alloy or any finished or semi-finished component containing tungsten heavy alloy.

(4) Tungsten metal powder; and (5) Tungsten heavy alloy or any finished or semi-finished component containing tungsten heavy alloy.

Section 844 adds molybdenum, gallium, and

How to check it without Arxo's tools

1. Open 10 U.S.C. (Armed Forces), OLRC release point 119-124 and find 10 U.S.C. 4872(f)(1)(E)-(F). Compare the text with the quotation above. A copy is kept in this register: 3a0a8808decb5adf-usc10-119-124.zip (SHA-256 3a0a8808decb5adf4469e23373a921cf23df1a38c460a56811ed3442ea9a6aa8, copy of the official file).
2. Open eCFR 48 CFR part 225 (currency through 2026-10-27) and find 48 CFR 225.7018-1, definition of covered material. Compare the text with the quotation above. A copy is kept in this register: 26bcbb8e4346b399-ecfr-48-225-2026-10-27.xml (SHA-256 26bcbb8e4346b399acd9786340b03a6505db0d74f48ecf0062338d85c547453b, copy of the official file).
3. Open DoD Class Deviation 2026-O0041, Revision 1 (July 1, 2026), Attachment A1: FAR Overhaul Part 25 and DFARS Part 225 and find Class Deviation 2026-O0041, Rev. 1: DFARS 225.7018-1 and clause 252.225-7961(a), definition of covered material. Compare the text with the quotation above. A copy is kept in this register: 4866b6f6f7f1f5fb-dfars-rfo-part225-rev1.pdf (SHA-256 4866b6f6f7f1f5fb1f99b4ca828cdb2c03885c29a6a9d474788a0470da2c9b79, copy of the official file).
4. Open Open DFARS cases as of October 23, 2026 (Defense Acquisition Regulations System) and find Open DFARS cases as of October 23, 2026, case 2024-D014. Compare the text with the quotation above. A copy is kept in this register: eb0de6e885c16743-dfars-open-cases.pdf (SHA-256 eb0de6e885c16743edd300a5f0a5b086f2e67bb3c255d2aa892199d54b46b7e4, copy of the official file).
5. The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.

How this finding was made

AI agents read the official texts and compared the provisions, clauses and preambles; they also drafted this record. A person at Arxo approved the report before it was sent.

Responsible institutions

• Department of Defense, Defense Pricing, Contracting, and Acquisition Policy — author of the DFARS and the class deviation

Reported to

Responses

No response recorded.

History

1. 2026-10-29Confirmed by Arxo
2. 2026-10-29Reported to Department of Defense, Defense Pricing, Contracting, and Acquisition Policy (e-mail)
3. 2026-10-31Entered in the register

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0244, https://arxo.io/findings/ARXO-2026-0244/ (status as of 2026-10-29). Data: ARXO-2026-0244.json.