What DFARS Specialty Metals Compliance Means for a Parts Buyer
DFARS specialty metals compliance means the titanium, zirconium, covered steels and covered nickel and cobalt alloys in DoD hardware were melted or produced in the United States, its outlying areas or, under 252.225-7009, a qualifying country, unless an exception applies. Buyers prove it with melt country on material certs and a compliance statement on the CoC.
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What does DFARS specialty metals compliance mean for a parts buyer?
It means every covered metal in the hardware you buy can be traced to a compliant melt, or is covered by an exception you can name. If your contract carries the clause and a shop machines your part from foreign-melted titanium bar, the part does not comply, however good it is.
The obligation sits with the prime contractor, but it flows down. DFARS 252.225-7009 requires the contractor to insert paragraphs (a) through (c) of the clause in subcontracts, including subcontracts for commercial products, for items containing specialty metals, and not to alter the clause beyond naming the parties. So a machine shop three tiers down working on a missile component is under the same melt rule as the prime. If you are the buyer at any tier, your job is to put the clause on the PO, make sure the supplier buys compliant stock, and keep the evidence.
Where does the specialty metals rule come from?
The statute is 10 U.S.C. 4863, titled "Requirement to buy strategic materials critical to national security from American sources; exceptions." It was originally enacted in 2006 as 10 U.S.C. 2533b and renumbered by the FY2021 National Defense Authorization Act, Public Law 116-283, with the renumbering taking effect January 1, 2022. Older contracts and supplier paperwork still say 2533b. It is the same law.
The statute bars DoD from acquiring aircraft, missile and space systems, ships, tank and automotive items, weapon systems and ammunition, or their components, containing specialty metal not melted or produced in the United States, and it also covers specialty metal bought directly by DoD or a prime contractor. DFARS implements it in subpart 225.7003: definitions, the restriction at 225.7003-2, the exceptions at 225.7003-3, and the clause prescriptions at 225.7003-5. The two contract clauses are 252.225-7008 and 252.225-7009.
The rule applies to contracts above the simplified acquisition threshold. FAR 2.101 sets that threshold at $350,000 for most purchases, after the inflation adjustment that took effect October 1, 2025, and DFARS 225.7003-3(a)(1) exempts acquisitions at or below it.
Have a part like this?Send it in under a minute. A person replies within 1 business day.Which clause is on my contract, 252.225-7008 or 252.225-7009?
Use 252.225-7008 when the deliverable is specialty metal itself, such as bar or plate sold to DoD. Use 252.225-7009 when the deliverable is a covered system or a component that contains specialty metal. Most machined, fabricated and assembled parts fall under 7009.
| 252.225-7008 | 252.225-7009 | |
|---|---|---|
| Title | Restriction on Acquisition of Specialty Metals | Restriction on Acquisition of Certain Articles Containing Specialty Metals |
| Current date | Mar 2013 | Jan 2023 |
| Prescribed when | Contract exceeds the simplified acquisition threshold and requires delivery of specialty metals as end items | Contract exceeds the simplified acquisition threshold and requires delivery of aircraft, missile or space systems, ships, tank or automotive items, weapon systems or ammunition, or their components, containing specialty metal |
| Where the metal must be melted or produced | United States or its outlying areas | United States, its outlying areas, or a qualifying country |
| Exceptions in the clause | None stated | Electronic components, COTS items with carve-outs, commercial fasteners, qualifying country manufacture, nonavailability determinations, 2 percent minimal content |
| Typical buyer | Government buying raw material, or a contract delivering stock | Primes and subs buying machined, formed, welded or assembled parts |
Outlying areas, per FAR 2.101, are Puerto Rico, the Northern Mariana Islands, American Samoa, Guam, the U.S. Virgin Islands and the U.S. minor outlying islands. Note the gap between the clauses: material melted in a qualifying country can satisfy 7009 but not 7008. If you are buying stock that will be delivered as stock, check which clause you are under before accepting a European or Canadian melt.
What counts as a specialty metal?
Titanium and zirconium in any alloy, nickel, iron-nickel and cobalt alloys with more than 10 percent of other alloying metals, and steels that exceed set alloy limits. Aluminum and copper alloys are not specialty metals.
| Category | Threshold in the clause | Shop floor examples |
|---|---|---|
| Steel (iron alloy with 0.02 to 2 percent carbon) | Maximum alloy content above 1.65 percent manganese, 0.60 percent silicon or 0.60 percent copper, or more than 0.25 percent of aluminum, chromium, cobalt, molybdenum, nickel, niobium, titanium, tungsten or vanadium | Stainless steels, and alloy steels whose chromium, nickel or molybdenum content passes 0.25 percent |
| Nickel and iron-nickel alloys | Alloying metals other than nickel and iron total more than 10 percent | Most nickel superalloys used in engines and hot structures |
| Cobalt alloys | Alloying metals other than cobalt and iron total more than 10 percent | Cobalt based wear and high temperature alloys |
| Titanium and titanium alloys | All | Commercially pure grades and Ti-6Al-4V |
| Zirconium and zirconium alloys | All | Zirconium alloys in specialized hardware |
Two definitions in the clauses catch people out. "Alloy" follows the name: a titanium alloy must contain 50 percent or more titanium by mass, and a two-metal name like iron-nickel needs those two to predominate and total at least 50 percent. "Produce" means atomization, sputtering, or final consolidation of non-melt-derived metal powders, so titanium and nickel alloy powder for additive manufacturing is covered by where it was atomized, not only where the ingot was melted. Treat a borderline steel grade as covered until you have checked its chemistry against the thresholds above. The library pages on titanium alloys, nickel superalloys and stainless and specialty steels cover the grades in more depth.
Which countries are qualifying countries?
DFARS 225.003 lists 28: 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 and the United Kingdom.
Under 252.225-7009, specialty metal melted or produced in any of them is acceptable, and so is an item manufactured in a qualifying country. Several large metal producing countries are not on the list, including China, India, Russia, Brazil, South Korea and Taiwan, so a cert showing one of those as melt country fails 7009 unless another exception applies. The list can change, so check DFARS 225.003 at the time you place the order rather than relying on a saved copy.
What are the exceptions?
The main ones in 252.225-7009 are electronic components, most commercially available off-the-shelf items, certified commercial fasteners, items made in a qualifying country, government nonavailability determinations, and the 2 percent minimal content allowance. DFARS 225.7003-3 also exempts whole acquisitions such as combat and contingency support buys, and allows a commercial derivative military article route under 252.225-7010.
Electronic components
Exempt. The clause defines an electronic component as an item that operates by controlling the flow of electrons or other charged particles in circuits, such as resistors, capacitors, diodes and integrated circuits. The definition excludes structural or mechanical parts of an assembly containing an electronic component, and excludes high performance magnets. A titanium chassis, a stainless connector shell or a machined housing around a circuit card is not exempt because the card is.
Commercially available off-the-shelf items
Exempt, with four carve-outs that stay covered: specialty metal mill products such as bar, billet, wire, slab, plate and sheet not yet incorporated into COTS end items, subsystems, assemblies or components; forgings and castings unless incorporated into COTS end items, subsystems or assemblies; commercially available high performance magnets unless incorporated into COTS end items or subsystems; and COTS fasteners unless incorporated into COTS items or covered by the fastener exception. COTS means sold in substantial quantities commercially and offered without modification. Metal added after acceptance is covered, and a military-unique option not normally offered commercially is covered. If COTS items are combined into a non-COTS item, only the specialty metal used to join them is subject to the restriction.
Commercial fasteners
Exempt if the fastener manufacturer certifies that, for the relevant calendar year, at least 50 percent of the specialty metal it buys for fasteners for all customers will be domestically melted or produced, in the required form.
Minimal content
An end item is exempt if its noncompliant specialty metal is no more than 2 percent of the total weight of specialty metal in the end item, estimated in good faith by the contractor. It never applies to specialty metal in high performance magnets.
Nonavailability and waivers
If compliant metal cannot be acquired as needed at a fair and reasonable price in satisfactory quality, sufficient quantity and the required form, the government can make a nonavailability determination. Under DFARS 225.7003-3(b)(5), the secretary of the military department concerned can do it for a single contract, and class determinations need the Under Secretary of Defense for Acquisition and Sustainment, with notice on SAM.gov at least 30 days ahead. A separate national security waiver is reserved to USD(A&S) and triggers a compliance plan. A buyer cannot grant any of these.
How does the 2 percent minimal content exception work in practice?
It is calculated at the end item, by weight of specialty metal, and the prime manages it. A subcontractor should not assume its part fits inside someone else's 2 percent.
The clause lets primes modify paragraph (c)(6) in subcontracts only as needed to manage the exception at the prime level. A prime may keep the whole allowance for itself and require full compliance from its suppliers. If you want to use it, get it in writing from your customer before you buy noncompliant material. Ask also whether your part could be the one that pushes the end item over.
How is compliance shown on certs and CoCs?
With two documents that agree: a material cert that states the country of melt, or for powder the country of production, and a supplier CoC that states compliance with the specific DFARS clause or names the exception relied on.
The clause itself does not prescribe a certificate format, so the proof is whatever links the metal in the part back to a compliant melt. That chain usually looks like this:
- Mill test report showing heat number and melt country. Some certs carry a DFARS or domestic melt statement; others only list melt location. Either works if it is specific to the heat.
- Distributor or cutter cert carrying the same heat number and the mill's melt country forward.
- Manufacturer's CoC listing the heat or lot used and stating the part complies with 252.225-7009, or naming the exception, such as a qualifying country melt.
- Fastener or COTS documentation where an exception is claimed, such as the fastener manufacturer's 50 percent certification.
Watch for certs that say "DFARS compliant" with no melt country, and for remelted material. For material that has passed through several distributors or processors, make sure the melt country comes from the original mill report, not from a reseller's address. For more on reading the paperwork, see material certs and traceability and our guide to the certificate of conformance.
What should a buyer put on the purchase order?
The clause number and date, the melt evidence you want, and a rule that any exception is approved by you before material is bought.
- DFARS 252.225-7009 (Jan 2023), or 252.225-7008 (Mar 2013) when stock is the deliverable, flowed down in full
- Material cert required showing heat number and country of melt, or country of atomization for powder
- Statement on the CoC of compliance with the cited clause, listing heat or lot numbers used
- Any exception the supplier intends to use, stated in the quote and approved in writing before purchase
- Seller to flow the clause to its own sub-tier suppliers, including material distributors and fastener sources
- Notification required if noncompliant metal is discovered after purchase
Put the same requirement in the RFQ so the quote is based on compliant stock. The aerospace RFQ checklist shows where it fits, and the defense contractors page covers other DoD flow-downs.
What mistakes cause specialty metals problems?
Most problems come from the requirement never reaching the person buying the metal.
- Clause on the prime contract but missing from the sub-tier PO
- Shop pulls bar from its own inventory with no record of melt country
- Assuming a stainless or alloy steel grade is not covered because it is "just steel"
- Treating a catalog bar or plate as COTS, when mill products are carved out
- Treating a machined housing as an electronic component because it holds electronics
- Accepting a qualifying country melt on a 252.225-7008 order
- Using the 2 percent allowance without the prime's approval
- Additive parts with no record of where the powder was atomized
For certified and surplus stock specifically, our certified aerospace material page explains how surplus is screened, and the metal additive manufacturing library page covers powder traceability.
Source compliant material and parts
Send the alloy, spec, size and the DFARS clause through the certified material request form. It asks for melt and cert requirements up front, which is what decides whether a piece of stock is usable on your contract. A person replies within 1 business day. We flow the clause down to the supplier, check the melt country and heat numbers on the certs against your PO before shipment, and every order ships with a certificate of conformance plus the material certs your request requires. If the drawing or the program is export controlled, see controlled programs before sending files.
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Part, quantity and date are enough to start. Drawings and the mutual NDA follow by reply, and controlled programs never send technical data through this site.
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Questions
Does DFARS specialty metals apply to aluminum?
No. The DFARS definition of specialty metal covers certain steels, nickel and iron-nickel alloys, cobalt alloys, titanium and zirconium. Aluminum alloys and copper alloys are not on the list, so an all-aluminum part does not carry a melt restriction under 252.225-7009. Steel fasteners, stainless inserts or titanium hardware installed in an aluminum assembly can still be covered, so check every material on the bill of materials.
Is 10 U.S.C. 4863 the same as 10 U.S.C. 2533b?
Yes. The specialty metals statute was enacted in 2006 as 10 U.S.C. 2533b and renumbered as 10 U.S.C. 4863 by the FY2021 National Defense Authorization Act, Public Law 116-283, effective January 1, 2022. The substance carried over. Older purchase orders, quality clauses and mill paperwork still cite 2533b, and that reference points to the same requirement.
Is Canadian or European melted titanium DFARS compliant?
It depends on the clause and the country. Canada and many European countries, including France, Germany, Italy, Spain, Sweden and the United Kingdom, are qualifying countries under DFARS 225.003, so their melt satisfies 252.225-7009. It does not satisfy 252.225-7008, which requires melting or production in the United States or its outlying areas. Check the current qualifying country list when you order.
Are COTS parts exempt from DFARS specialty metals?
Mostly, but not completely. Commercially available off-the-shelf items are exempt under 252.225-7009, except specialty metal mill products like bar, plate and sheet, forgings and castings, high performance magnets, and COTS fasteners when they are not incorporated into COTS items. The item must be sold in substantial quantities commercially and supplied without modification, and military-unique options are not exempt.
Who is responsible for the 2 percent minimal content exception?
The prime contractor. The 2 percent is measured against the total weight of specialty metal in the end item, estimated in good faith by the contractor, and the clause only lets the prime modify that paragraph in subcontracts to manage the exception at its level. Subcontractors should not use it without written approval. It never applies to high performance magnets.
Does DFARS specialty metals apply to 3D printed parts?
Yes, when the part contains specialty metal and the contract carries the clause. DFARS defines produce to include atomization, sputtering and final consolidation of non-melt-derived metal powders, so titanium or nickel alloy powder must be produced in the United States, its outlying areas or a qualifying country under 252.225-7009. Ask the powder supplier for the country of atomization on its cert.
What does a DFARS compliant material cert look like?
It identifies the heat or lot and states where that heat was melted, or for powder where it was produced. Some mills add a statement of compliance with DFARS 252.225-7009 or domestic melt. A cert that says DFARS compliant without a melt country is weaker evidence, so ask for the mill report behind it, and make sure every distributor cert carries the same heat number.
Related
Sources
- Cornell LII, 10 U.S.C. 4863 Requirement to buy strategic materials critical to national security from American sources
- Acquisition.gov, DFARS 252.225-7009 Restriction on Acquisition of Certain Articles Containing Specialty Metals (Jan 2023)
- Acquisition.gov, DFARS 252.225-7008 Restriction on Acquisition of Specialty Metals (Mar 2013)
- Acquisition.gov, DFARS 225.003 Definitions (qualifying country)
- Acquisition.gov, DFARS 225.7003-2 Restrictions
- Acquisition.gov, DFARS 225.7003-3 Exceptions
- Acquisition.gov, DFARS 225.7003-5 Solicitation provision and contract clauses
- Acquisition.gov, FAR 2.101 Definitions (simplified acquisition threshold, outlying areas)
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