Trade & Domestic Content
Domestic component cost threshold for manufactured products
U.S. manufacturing requirement for iron and steel
New infrastructure funding subject to BABA
Regulation Overview
BABA is the most expansive domestic content procurement preference in U.S. history and the cornerstone of federal infrastructure sourcing policy. For supply chain teams, the primary obligation is proving that every product on federally funded projects meets category-specific domestic production standards.
The Act covers three product categories with distinct thresholds. Iron and steel require 100% domestic manufacturing from melting through coating. Manufactured products must undergo final assembly in the U.S. with greater than 55% of component costs from domestic sources. Construction materials require all manufacturing processes domestically.
BABA compliance requires certified origin evidence—manufacturing locations, component costs, and self-certification letters—from every supplier. When agencies rescind waivers or update guidance, your entire portfolio requires reassessment.
Key Components / Sub-Frameworks
Federal grant recipients and subrecipients managing infrastructure projects
General contractors and subcontractors on federally funded construction
Manufacturers supplying iron, steel, or manufactured products to covered projects
Construction material suppliers (non-ferrous metals, plastics, glass, lumber, drywall)
Equipment manufacturers selling into BEAD, DOE, EPA, or DOT-funded programs
Distributors and wholesalers in the federal infrastructure supply chain
Key Thresholds
Your project uses 200 products from 85 suppliers. Each requires a BABA self-certification letter classifying the product and attesting domestic origin—but half your suppliers have never heard of BABA. Your team spends weeks reviewing generic letters against three different product standards, then months chasing corrections.
A manufactured product has 40 components from 12 suppliers across 3 countries. You need acquisition costs for each component to calculate domestic content. Transportation costs count. Duties count. Labor does not. One supplier changes a subcomponent source and your entire calculation flips. Without automated cost tracking, you're rebuilding spreadsheets for every product.
No domestic source exists for a critical component. You need a nonavailability waiver—but each federal agency runs its own process with different timelines and documentation standards. HUD, EPA, DOE, and DOT each have separate portals. A waiver granted by one agency doesn't apply to another. Your team tracks status across five agencies simultaneously.
Your company supplies products to projects funded by DOT, EPA, and DOE simultaneously. Each agency interprets BABA differently. DOT just rescinded its manufactured products waiver. EPA has 50+ implementation FAQs. DOE runs a separate waiver page. The same product requires different documentation depending on which agency funded the project.
Certivo In Action
BABA Workflow
Construction Materials
Pain Point
Must prove origin of every material before federal funds release
Electronics Manufacturing
Pain Point
BEAD and DOE funding require domestic manufacturing proof
Energy & Infrastructure
Pain Point
EPA-funded projects require BABA for pipes, valves, treatment equipment
Automotive Manufacturing
Pain Point
FHWA waiver rescission creates new manufactured products obligations
Government & Public Sector
Pain Point
Grant recipients must enforce BABA compliance across all subrecipients and contractors
Semiconductor & High-Tech
Pain Point
BEAD program requires domestic manufacturing for network hardware
Industrial & Heavy Equipment
Pain Point
Heavy equipment requires 55% domestic component cost proof
Medical Devices & Equipment
Pain Point
HUD-funded projects subject to BABA for medical facility equipment and construction materials
From Manual Review to Automated Validation
CORA-powered regulatory intelligence extracts origin data and calculates thresholds automatically. Your team focuses on waiver strategy—not chasing supplier letters.
BABA Documentation Acceleration
Generate complete, audit-ready project compliance packages in hours—not the 3+ weeks of manual compilation.
Proactive BABA Compliance Monitoring
When agencies rescind waivers or tighten requirements, Certivo reassesses your portfolio instantly. Know which products are affected before you bid.
Key Statistics
Frequently Asked Questions
How does Certivo track changes to BABA requirements across agencies?
Certivo monitors implementation guidance from DOT, EPA, DOE, HUD, USDA, and NTIA continuously. When agencies rescind waivers or update product standards, the platform reassesses your portfolio and alerts you to affected products—before your next bid is due.
What certification formats does Certivo accept from suppliers?
Certivo accepts any format: PDF certification letters, Excel cost breakdowns, typed attestations, and structured portal submissions. CORA-enabled analysis extracts origin and cost data regardless of format, eliminating the need to standardize templates across your supply base.
How does Certivo handle the 55% domestic component cost calculation?
Certivo extracts component-level cost data from supplier certifications, categorizes each component as domestic or non-domestic, and calculates the percentage automatically. Transportation costs and duties are included; labor and overhead are excluded per 2 CFR Part 184—with a full audit trail for every calculation.
Does Certivo support compliance across multiple federal agencies?
Yes. Certivo validates against BABA requirements from DOT, EPA, DOE, HUD, USDA, and NTIA simultaneously. Agency-specific templates generate compliant documentation for each funding source without separate data collection or parallel tracking systems.
How does BABA relate to the Buy American Act?
The Buy American Act governs direct federal procurement with a 65% threshold. BABA governs federally funded infrastructure grants with a 55% threshold for manufactured products. Different definitions, cost methods, and waiver processes apply. Certivo validates supplier evidence against both frameworks from a single data collection.