August 27, 2026 through August 27, 2027. Covered sellers face a 100% monthly domestic sales requirement unless BIS grants an adjustment or exception.
Treat location as a transaction control
The BIS rule states that covered black mass and tungsten waste and scrap must remain physically located in the United States unless otherwise authorized. Capture origin, destination and evidence references for each covered movement.
Use source records, not a checkbox alone
Bills of lading, warehouse records, delivery confirmations and other business records can support the internal evidence trail. The specific evidence appropriate to a transaction depends on the company’s process.
Link authorizations directly
If BIS authorizes an adjustment or exception affecting location or sale, connect the authorization record to the affected transactions and preserve its terms.
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.