DPAS Covered-Material Sales Compliance & Evidence System

The rule is live. The evidence has to exist before anyone asks for it.

BIS's temporary final rule places a 100% monthly domestic sales requirement on covered black mass and tungsten waste and scrap sold by U.S. persons. Covered material generally must remain physically located in the United States unless BIS authorizes otherwise. The rule also preserves rated-order obligations and provides a process for adjustments, exceptions and interim relief.

The Syntera system turns that operating requirement into a repeatable internal record: what material was sold, how it was classified, who bought it, what evidence supports buyer status and physical location, how the AES/EEI shipment-control and release workflow was completed when applicable, whether an authorization applies, and how the month was reviewed.

Working areas included

• Start Here — requirements, workflow and operating instructions
• Compliance Dashboard — monthly sales, evidence gaps, exceptions and status
• Material Classification — covered-material determinations and Schedule B references
• Buyer Diligence — U.S.-person verification and supporting evidence
• Sales Register — transaction-level quantity, value, buyer, location and control status
• BIS Requests — adjustments, exceptions, temporary licenses, appeals and inability-to-comply matters
• Evidence Index — invoices, bills of lading, location records, diligence and BIS correspondence
• AES/EEI Shipment Control & Release — document filing status, shipment holds, release review and retained filing evidence when the workflow applies
• Monthly Review — month-end compliance review and sign-off
• Authority & Change Log — regulatory basis and future changes

Read the free guide: DPAS Directive Allocation Order Compliance Checklist