An Overview of DFARS Material Compliance for Metal Fabricators

Navy submarine with an American flag.

Defense Federal Acquisition Regulation Supplement (DFARS) — it’s a mouthful. But for precision metal fabricators who perform work for our nation’s military, it’s a critically important aspect of their business.

To become a government-approved metal fabricator, companies need to be DFARS compliant and demonstrate that their flow downs and purchasing practices adhere to government regulations.

DFARS compliance covers everything from contract clauses, supply chain management, accounting standards, and more. It also covers cybersecurity requirements, which we’ve written about before

Today, our focus is on the complex world of DFARS material procurement.

What is DFARS?

DFARS stands for Defense Federal Acquisition Regulation Supplement and generally applies to procurement contracts for the Department of Defense (DoD). It is intended to protect classified information, safeguard controlled unclassified information (CUI), implement cybersecurity standards, stipulate material acquisition, and a host of other requirements. DFARS also aims to award defense contracts in a fair, efficient, and transparent manner.

DFARS-Approved Countries

As part of DFARS compliance, contractors are required to follow the Buy American Act and Trade Agreement Act, which stipulate limits on the sources of origin for certain materials. According to official government sources, qualifying countries have been approved due to their mutual understandings and international agreements for purchasing supplies. 

Qualified DFARS countries include:

  • Australia
  • Austria
  • Belgium
  • Canada
  • Czech Republic
  • Denmark
  • Egypt
  • Estonia
  • Finland
  • France
  • Germany
  • Greece
  • Israel
  • Italy
  • Japan
  • Latvia
  • Lithuania
  • Luxembourg
  • Netherlands
  • Norway
  • Poland
  • Portugal
  • Slovenia
  • Spain
  • Sweden
  • Switzerland
  • Turkey
  • United Kingdom of Great Britain and Northern Ireland

Sometimes, a contractor may specify that materials are melted and manufactured in the United States rather than an approved country. In such cases, it needs to be spelled out in advance during the quoting process to help accurately forecast costs and lead times. 

DFARS Materials

Materials intended for use on DoD naval vessels and other defense projects must comply with DFARS. The following specialty materials are most relevant to metal fabrication companies:

  • Steel
  • Metal alloys made of nickel or iron-nickel
  • Zirconium, zirconium alloys
  • Titanium, titanium alloys
  • Cobalt base alloys

Most commercial off-the-shelf (COTS) parts, such as screws, hardware, helicoil inserts, and rivnuts, must also be acquired from certified distributors. For example, the DOD prohibits the use of some magnets and tungsten from North Korea, China, Russia, and Iran.

Thorough documentation in the form of material certifications must accompany all parts and materials to confirm their origin, quality, and chain of custody. While procurement is a critical aspect of compliance, so is accurate recordkeeping and reporting. Learn more about the importance of the quality data package (QDP) as part of project fulfillment in our related article.

RELATED: Quality Data Package (QDP) Considerations

Tips for RFPs With DFARS Compliance Requirements

Can anyone ever be a DFARS compliance “expert?” The reality is that DFARS regulations span thousands of pages containing government jargon and details, making it difficult to be proficient. But government contractors still need the ability to decipher the necessary information that applies to their specific projects. 

Fox Valley Metal-Tech is well-acquainted with relevant metal fabrication DFARS requirements because of our extensive work on defense-related fabrications for naval ships and other defense programs. This includes complex doors and hatches and large electrical enclosures for electromagnetic aircraft launching systems (EMALS) and advanced arresting gear (AAG) systems. 

The vast expanse of DFARS regulations stresses the importance of outlining any compliance requirements in a request for proposal (RFP). At Fox Valley Metal-Tech, we have a strong grasp on what it takes to be in compliance. That said, our team needs to be in-the-know early in the quoting phase to ensure accurate pricing and projected lead times. Omission of DFARS requirements could significantly impact pricing based on availability and specifications.


Among the projects we completed with extensive DFARS compliance specifications were hundreds of large complex electrical enclosures for the Gerald R. Ford-Class Nuclear Aircraft Carrier. View our DoD Custom Electrical Enclosure Case Study to learn about how we helped reduce the DoD’s planned installation time by an impressive 75% because of our attention to detail and precise-tolerance capabilities. And contact our team of technical experts to talk through your next project.

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