Updates to Build America, Buy America Requirements

Moe Madar, North America Regulatory & Market Manager, Reflective Solutions

February 4, 2025

Updates to Build America, Buy America Requirements

On January 14, 2025, the FHWA announced that it was updating its "Buy America requirements to promote domestic manufacturing in transportation projects." The update, published as a rule in the Code of Federal Register (CFR), goes into effect in March 2025, and requires that "manufactured products" used in federal-aid highway projects once again comply with Buy America, Build America (BABA) requirements, and be domestically produced.

 

For a manufactured product to be BABA compliant, it must be produced in the US, and at least 55% of its material costs (not labor, shipping, etc.) must come from domestically-sourced components, such as US-made sheeting from Avery Dennison. The classification of an article, material, or supply "must be based on its status at the time it is brought to the work site for incorporation into an infrastructure project" (see 2 CFR 184.4(e)(2)).

 

Here are some important dates to note:

  • On October 1, 2025 the "final assembly requirement" will go into effect, meaning manufactured products must undergo final assembly in the United States beyond this date.

  • On October 1, 2026, the "55% rule" will go into effect, meaning the cost of American-made components of a manufactured product must equal or exceed 55% of the total cost of the product beyond this date.

If you need additional information regarding BABA and how it impacts traffic sign fabrication and work zone devices, contact Avery Dennison customer service or your local Avery Dennison representative.

 

Avery Dennison is proud to be a US manufacturer. Our best-in-class prismatic products are manufactured in Illinois and shipped around the world. We look forward to supporting our industry partners with this transition. Visit our website to learn more about our rich history, which dates back to the invention of prismatic signs in the 1920s.

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