ARTICLE · 19 NOVEMBER 2020

Significant Buy American Changes Are Coming Soon

Bradley

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Next, for everything else, the proposed rule increases the domestic content requirement from 50% to 55% percent "of the cost of all components."

United StatesGovernment, Public Sector

Aron C. Beezley

The Federal Acquisition Regulation Council recently released a proposed rule to implement the requirements of the Maximizing Use of American-Made Goods, Products, and Materials Executive Order, which was signed by President Trump on July 15, 2019. As discussed below, the proposed rule contains important amendments regarding domestic component thresholds and domestic pricing preferences, as well as reintroduces the domestic content test for commercially available off-the-shelf (COTS) items as it relates to certain steel and iron products.

Domestic Content Cost Threshold Changes

First, the proposed rule increases the "domestic content requirement for iron and steel end products" from 50% to 95%, meaning that at least 95% of the content (determined by the cost of the components) for end products or construction materials that consist wholly or predominantly of iron or steel (or a combination of both) must be mined, produced, or manufactured in the United States.

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