DFARS (Defense Federal Acquisition Regulation Supplement)
If you’re selling fasteners to the military, you may have already received requests from customers for a “DFARS Compliant” cert. What does that mean and how far must you go to comply?
A bit of history is in order. DFARS is part of the “Buy American Act,” which has been around since 1933. Joseph Smyth, in an article published in the “Acquisition Review Quarterly,” (Summer 1999), notes that this legislation has been used throughout our history “…to provide a preferential treatment for domestic sources of un-manufactured articles, manufactured goods, and construction materials. …The Act remains a Depression-era reminder of the protectionist policies of the United States prior to World War II.”
DFARS seems to follow the original intent of the Buy American Act, but the threat of sabotage and terrorism makes it seem less politically motivated. DFARS clause 252.209-7001—“Disclosure of Ownership or Control by the Government of a Terrorist Country,” lists Cuba, Iran, Libya, North Korea, Sudan, and Syria as known terrorist countries. As such, supplying the military with metal parts made from materials melted in these countries is prohibited “…unless a waiver is granted by the Secretary of Defense.”
There should be a clarification made here. As fastener distributors and manufacturers, we are not certifying that parts supplied are “DFARS Compliant.” DFARS is a very extensive document and compliance with all of its provisions would be virtually impossible. Rather, the clause in question here is DFARS 252.225-7014, “Preference for domestic specialty metals.” This means that any fasteners sold to the military made from certain metals as identified by this clause (stainless steel, beryllium copper, for example) must have had these metals melted in this country or in a qualifying country (clause 225.872-1—mostly western European countries) and you must provide evidence of this.
Rotor Clip provides DFARS certification for its retaining rings/hose clamp products for a $30 charge. Here’s what’s involved:
- All part numbers have to be traced back to the lot and heat from which they were produced in order for a clear and accurate cert to be issued. This is why we are unable to give an answer at the time of order; we won’t know the lot number until the part is actually picked and readied for shipment. (Parts are often produced from several different lots of material).
- Once a lot number is known, it is checked against a database to determine the supplier and heat number from which it was produced.
- The heat number and date it was produced are compared against current “certification letters” we have received from the supplier to determine if it is covered by any of these statements.
- If it is covered in the supplier’s cert letter, then a cert is issued which includes a copy of this statement.
- If it is covered in the supplier’s cert letter, then a cert is issued which includes a copy of this statement.
- If the part is not covered by the supplier’s documentation, then we must contact them to determine if the melt source for the heat in questions is DFARS compliant.
These extra steps required to provide an accurate DFARS certification statement are the reasons for the $30 charge.
