Domestic Content Lite — Buy American and BABA: Component-Level Declaration, Dated Thresholds, Waivers (free)

The problem, before the solution

A supplier to the US federal government signs, with its offer, a certification: the Buy American Certificate. It states that each of its end products is a domestic end product. Behind that term lies a calculation, and the calculation is done component by component — FAR 25.003:

“The cost of its components mined, produced, or manufactured in the United States exceeds 60 percent of the cost of all its components, except that the percentage will be 65 percent for items delivered in calendar years 2024 through 2028 and 75 percent for items delivered starting in calendar year 2029 […] Components of unknown origin are treated as foreign.”

Three things are at stake, and a spreadsheet misses all three.

The threshold is not a number, it is a dated number. 60%, then 65%, then 75%. And what decides is the year of delivery — FAR 25.101(d)(1): “shall be required to comply with each increased threshold for the items in the year of delivery”. A contract whose performance spans 2028 and 2029 falls under two thresholds.

Components of unknown origin count as foreign. This is not a cautious option, it is the text. An empty cell in a spreadsheet counts nowhere; here, it counts against you.

Three tests coexist, and they never mix. 60/65/75% for ordinary supplies; less than 5% foreign iron and steel for products consisting predominantly of iron or steel; more than 55% for the manufactured products of a BABA project. Applying 55% to a supply contract is the costliest mistake in this area.

What it does

• Declarations per finished product — regime, delivery year, product type, BABA category where applicable. The regime determines the test, the delivery year determines the threshold, and nothing is guessed.

• Components — one line per component: product or free-text label, country of origin, cost within the meaning of FAR 25.003 (transport and duties included, profit excluded), iron and steel share, COTS flag. Components with no declared origin are counted as foreign and counted separately, because that is often where a file's margin lies.

• Table of DATED thresholds — sixteen thresholds, each with its validity period, its reference and a verbatim quotation of the text it is based on. A single method returns the threshold in force on a given date; every calculation in the module goes through it.

• BABA waiver register — the three grounds of 2 CFR 184.7(a) and nothing else, with the dates of the public process and the comment period.

• The two COTS checkboxes — and there really are two. The content exemption applies to COTS end products; it does not apply to iron and steel products, except for COTS fasteners. A single checkbox would have let a steel frame pass as a bolt.

The threshold that starts empty, and must stay that way

FAR 25.105, “Critical components and critical items”, was read in full: its list is [Reserved]. No critical item and no additional preference factor is in force. The module therefore ships this threshold with no value, together with its caveat, and produces no enhanced-preference finding as long as no value is entered. Setting zero would have given the same arithmetic result — but a displayed zero reads as a verified value, which is exactly the opposite of what is needed.

What it does not do

• Import of components from a bill of materials mrp.bom, with the cost taken from the product and the origin carried over when it exists.

• Multi-level rollup of a bill of materials made of bills of materials.

• Generation of a certification statement following the structure of FAR 52.225-2.

• Comment deadlines for waivers, and flagging of a period that is too short.

• Sensitivity analysis: the threshold at which this product tips over.

• The reference registry connector, plugged into the base module's source chain.

All of this belongs to the full edition, Domestic Content — Buy American & BABA. The two modules install on top of each other: nothing needs to be re-entered.

The module records findings; it does not draw conclusions

It says: “the calculated rate is 61.2%, the threshold for delivery year 2026 is 65%” and “three components have no declared origin”.

It never says “this product is not compliant” or “the certification can be signed.” This is not drafting caution: the Buy American certification is an attestation signed by the offeror, and a false certification binds its signatory. Software that drew the conclusion in their place would turn a data entry error into criminal exposure.

Not proven in production

This module has not been tested against any actual filing, agency system or audit. The regulatory citations it carries were taken from the official texts on September 14, 2026 — FAR as of FAC 2026-01, 2 CFR current as of September 10, 2026; they do not replace the advice of your contracting officer. Start with a trial file and about ten components.