Federal-aid highway program
FHWA BABA rules for manufactured product
How the Build America, Buy America manufactured product standard applies to a project funded by Federal Highway Administration. The cited rule, a worked example, and the waiver options.
Run it in the calculatorA manufactured product permanently incorporated into the project must be manufactured in the United States (the final assembly requirement). The 55 percent domestic component-cost test does not apply to projects obligated before October 1, 2026.
A worked example
Take HDPE pipe, a plastic and polymer-based construction material, supplied to a FHWA project. Every manufacturing process has to occur in the United States.
- Resin productionUnited States
- CompoundingUnited States
- ExtrusionUnited States
- Finishing and markingUnited States
Every step above is in the United States, so this example is compliant. Move a single step offshore, for example extruding the pipe abroad from US resin, and the whole item is non-compliant. There is no percentage that rescues it; the standard is all-or-nothing.
How to check a line
- 1
List every manufacturing step
List each manufacturing process the manufactured product goes through, from the earliest stage to final finishing.
- 2
Record the location of each step
For each step, record the country where it was performed.
- 3
Confirm all steps are in the US
The item passes only if every listed manufacturing process occurred in the United States. One offshore step fails the whole item.
- 4
Handle any shortfall
If any step was performed abroad, the item is non-compliant. Check whether a waiver category applies before relying on it.
FHWA manufactured product questions
What is the manufactured product standard for a FHWA project?
A manufactured product permanently incorporated into the project must be manufactured in the United States (the final assembly requirement). The 55 percent domestic component-cost test does not apply to projects obligated before October 1, 2026.
Is there a percentage to hit?
No. This is an all-or-nothing standard: every manufacturing process must occur in the United States. A single offshore step fails the item, regardless of cost.
What if a manufactured product line fails the standard?
It is non-compliant unless a recognised waiver applies and is granted by the agency. FHWA recognises 5 waiver categories. A waiver is never a pass on its own.