If you supply parts for U.S. defense programs, you’ve likely seen “DFARS compliant” on a purchase order or drawing. It’s shorthand for the Department of Defense rules on where certain metals are melted.
DFARS is the Defense Federal Acquisition Regulation Supplement, the Department of Defense’s purchasing rules. Two of its clauses deal with specialty metals, and they don’t say quite the same thing.
The two DFARS clauses
| Clause | Applies to | Specialty metal must be melted or produced in |
|---|---|---|
| DFARS 252.225-7008 — Restriction on Acquisition of Specialty Metals | Specialty metal delivered to the government as the metal itself | The United States or its outlying areas |
| DFARS 252.225-7009 — Restriction on Acquisition of Certain Articles Containing Specialty Metals | Specialty metal built into parts and products delivered to the government | The United States, its outlying areas, or a qualifying country |
Many manufacturers who buy strip from us make parts that go into defense products, so 252.225-7009 is the clause they usually see flowed down. It accepts metal melted in a qualifying country as well as in the United States. Clause 252.225-7009 also has exceptions of its own, so the clause in your contract and its terms decide what applies.
Qualifying countries
A qualifying country is one with a reciprocal defense procurement agreement with the United States, as defined in DFARS 225.003. At the time of writing, they are:
The list can change, so check the current DFARS definition before relying on it.
Which metals are “specialty metals”
Both clauses use the same definition. Specialty metals are:
- Steels with more than 0.25% of chromium, nickel, molybdenum, cobalt, niobium, titanium, tungsten, vanadium or aluminum — or more than 1.65% manganese, 0.60% silicon or 0.60% copper
- Nickel and iron-nickel alloys with more than 10% of other alloying metals
- Cobalt alloys with more than 10% of other alloying metals
- Titanium and zirconium and their alloys
For the materials we stock, that means:
| Material | Specialty metal? |
|---|---|
| 300 and 400 series stainless | Yes |
| 17-7PH® stainless | Yes |
| Alloy 625 | Yes |
| 1008 / 1010 low carbon steel | No |
| C17200 beryllium copper | No |
Stainless steels qualify because of their chromium (and, in the 300 series, nickel) content. Low carbon steel and beryllium copper fall outside the definition, so neither clause applies to them.
Where our material comes from
| Material | Melted | Rolled |
|---|---|---|
| Stainless steels (300 & 400 series, 17-7PH®) | USA | USA |
| Alloy 625 | USA | USA |
| 1008 / 1010 low carbon steel | USA | USA |
| C17200 beryllium copper | Japan | USA |
Our stainless steels and Alloy 625 — the specialty metals we stock — are melted and rolled in the USA. U.S. melt satisfies both clauses, so they meet 252.225-7008 and 252.225-7009 alike, and you don’t need to sort out which clause your contract uses. Our 1008 / 1010 low carbon steel is U.S. melted and rolled as well, which matters to many customers whether or not their work falls under DFARS.
Our beryllium copper is melted in Japan and rolled in the USA. Because beryllium copper is not a specialty metal under the DFARS definition, these clauses don’t restrict where it is melted. (Japan is also a qualifying country, though that doesn’t come into play here.)
How it shows on your paperwork
Country of melt is cited on the Brown Metals Company Certificate of Conformance / Test that ships with your order.
Full mill certifications, including the melt mill’s certification, are also available by request. Mill certifications cite the melt location as well.
If your order calls for DFARS compliance, note it on your request for quote so it carries through to your certifications.
This article is educational information only and is not legal advice. The requirements that apply to your contract are set by its terms and the current DFARS; confirm them with your contracting officer.