DFARS Compliance 

Guidelines for ensuring that you are compliant with Clause 252.225-7009 when required:

  1. Procurement: The purchase order for the raw material must state that DFARS compliance is required. Without the DFARS criteria,  your raw metal supplier may send you titanium or stainless steel from China or Russia.  These two countries are not on the Qualifying Country List.
  2. Incoming Receiving Personnel: The Mill Test Report states that the material was Melted in the USA or Qualifying Country.
  3. Quality Assurance: Verify the Mill Test Report is compliant.  The document must be legible.  A record of the test report must be retained for the duration specified by the PO.

What is DFARS?

It is usually the responsibility of the Quality Manager in most manufacturing facilities to ensure the products manufactured meet customer requirements.  In addition to the dimensional requirements defined on the drawings, the company must provide certifications and inspection reporting based on the criteria customers define on their purchase orders.

Many times, a defense or aerospace related purchase order will require compliance to DFARS.  You may be wondering, what in the world is DFARS?  DFARS is simply the rules of acquisition for defense organizations in the United States.

DFARS Definition

DFARS (Defense Federal Acquisition Regulation Supplement) -  A supplement to the FAR (Federal Acquisition Regulation) that provides DoD-specific acquisition regulations that DoD government acquisition officials and those contractors doing business with DoD must follow in the procurement process for goods and services. 

One of the most common purchase order requirements of Defense customers is DFARS Clause 252.225-7009 Restriction on Acquisition of Certain Articles Containing Specialty Metals.  The clause specifies: All Titanium, Stainless Steel, and other "Specialty Metals" must be melted in the United States or a "Qualifying Country".  This is a very important requirement to understand, especially if you deal in titanium and stainless materials. 

What Is A Qualifying Country?

DFARS - Qualifying Country - means a country with reciprocal defense procurement memorandum of understanding or international agreement with the United States, in which both countries agree to remove barriers to purchases of supplies produced in the other country or services performed by sources of the other country, and the memorandum or agreement complies, where applicable, with the requirements of section 36 of the Arms Export Control Act (22 U.S.C. 2776) and with 10 U.S.C. 2457.

 DFARS Qualifying Countries



For more information on DFARS, visit http://www.acq.osd.mil/dpap/dars/dfarspgi/current/.


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