In July 2008, DOD proposed revisions to the Specialty Metals rules, hoping to finally calm the turbulence that has boiled up over the past three years in this area. On July 29, 2009, after more than a year of stolid deliberation, DOD issued final rules implementing the latest statutory revisions from January 2008. See 74 Federal Register 37626.

We have discussed the specialty metals restrictions at some length in this blog. Frankly, we wish that such extensive discussion was unnecessary and that the whole specialty metals regulatory framework would be better streamlined (or, at the risk of over-wishing, that it would just go away). We have heard from many people in industry that the chaos and impenetrability of the specialty metals regulations serve as an archetypal example of why doing business with the United States is so difficult. Rather than re-hashing matters we have already discussed, this blog posting discusses key features of the new DOD specialty metals rules, highlighting some of the key differences between the final and proposed rules (there are few).