August 27, 2026 through August 27, 2027. Covered sellers face a 100% monthly domestic sales requirement unless BIS grants an adjustment or exception.
Black mass coverage is narrower than the Schedule B headings alone
The rule identifies three Schedule B codes for battery waste and scrap, but the domestic sales requirement applies under those codes only when the material meets the rule’s black-mass definition. Document the factual basis for the classification instead of treating every item under the codes as automatically covered.
Track each covered sale
For covered black mass, maintain buyer identity, quantity, value, date, classification, location and supporting records. The transaction register should tie back to the monthly review.
Preserve physical-location evidence
Covered black mass generally must remain physically located in the United States unless otherwise authorized by BIS. Build the location record into the transaction process rather than reconstructing it later.
Build the evidence while the transaction is current
The Syntera DPAS Covered-Material Sales Compliance & Evidence System organizes material classification, buyer diligence, sales, physical-location evidence, BIS requests, supporting documents and month-end review in one Excel control system.
Official source
This guide is based on the BIS temporary final rule published August 6, 2026. Read 91 FR 50701–50706.
Educational information and operational control guidance only. Not legal advice or a determination that any particular material, buyer or transaction is covered.