A recently-issued federal directive effectively prohibits the export of black mass for any domestic company from the United States, unless an exception or adjustment is obtained from the Department of Commerce The Directive took effect on August 27, 2026, and remains in effect for approximately one year from the date of publication. If the Company is unable to obtain an exception, the Company will not be able to sell black mass to foreign customers, which could result in a material adverse effect on its revenue, results of operations, financial condition, and ability to fund ongoing operations. Sales of black mass represent the majority of the Company’s total revenue, and substantially all of its current black mass customers are located outside the United States. The Company has submitted a request for an exception from the Directive’s domestic allocation requirement and is actively engaging with Congressional representatives, government affairs advisors, and other stakeholders regarding this matter. Under the Directive, companies may submit exception requests on a rolling basis, and BIS intends to respond within 14 days of receipt.

The Company is monitoring developments regarding the Directive, including the public comment period (which remains open until November 4, 2026), potential legislative action, and any modifications BIS may make to the Directive or exception process. The Company intends to pursue all available avenues to obtain relief, but it cannot predict the outcome of these efforts or their timing.