What Is DFARS Compliance and Why It Matters for Aluminum Procurement

What DFARS Is

The Defense Federal Acquisition Regulation Supplement is a set of regulations that supplement the Federal Acquisition Regulation for contracts with the U.S. Department of Defense. It imposes requirements that go beyond standard commercial procurement, including cybersecurity controls, counterfeit parts prevention, and specialty metals compliance. DFARS is codified in Title 48, Chapter 2 of the Code of Federal Regulations, and the specialty metals clause specifically is found at 252.225-7014.

The Specialty Metals Clause (252.225-7014)

DFARS 252.225-7014 prohibits the acquisition of specialty metals that were not melted in the United States or a qualifying country, or that were not manufactured from compliant specialty metals. Aluminum is explicitly listed as a specialty metal under the clause. When this clause appears in a prime contract, it flows down to subcontractors and suppliers throughout the supply chain - meaning distributors and material suppliers must be able to certify the origin of the metal they provide.

What Qualifies as DFARS-Compliant Aluminum

For aluminum plate to be DFARS-compliant, the metal must be melted in the United States or a DFARS qualifying country, and it must be manufactured (rolled, heat treated, and processed) in the United States or a qualifying country. Both melt and manufacture must be compliant - metal melted in the U.S. but rolled in a non-qualifying country does not meet the requirement. Domestic mills including Constellium, Kaiser, and Arconic/Novelis produce DFARS-compliant plate and can certify both melt and manufacture origin.

DFARS Qualifying Countries

The list of qualifying countries is defined in DFARS 225.872-1 and is updated periodically. Current qualifying countries include Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Egypt, Finland, France, Germany, Greece, Israel, Italy, Luxembourg, Netherlands, Norway, Poland, Portugal, Spain, Sweden, Switzerland, Turkey, and the United Kingdom. Aluminum melted and manufactured in any of these countries meets the specialty metals requirement.

• United States (domestic mills)
• Canada
• United Kingdom
• Germany
• France
• Australia
• Norway
• Other NATO and allied nations per 225.872-1

How to Verify Compliance

The primary verification document is the mill certificate (material test report). A compliant mill cert should state the country of melt (heat origin) and country of manufacture, along with the mill name and location. For domestic material, the mill name and address confirm manufacture. If the country of origin is not stated on the cert, request a supplemental Certificate of Conformance from the distributor explicitly certifying DFARS compliance. Some distributors maintain DFARS certs as a separate document alongside the standard MTR.

Consequences of Non-Compliance

Using non-DFARS material in a contract that requires it can result in stop-work orders, rejection of the delivered item, contract termination for default, and - in cases involving knowing misrepresentation - False Claims Act liability with treble damages. Even if the error was inadvertent, the contractor remains responsible for the compliance of materials throughout their supply chain. The risk is asymmetric: the cost of verifying compliance upfront is trivial compared to the cost of a non-conformance at delivery or audit.

When DFARS Is Required vs Optional

DFARS 252.225-7014 applies when the clause is present in the prime contract and flows down to subcontractors. It does not apply to commercial-off-the-shelf (COTS) items, to contracts below the simplified acquisition threshold for commercial items, or to contracts for non-specialty-metal items. If you are unsure whether your contract is subject to the specialty metals clause, your contracts department or the contracting officer can confirm. When in doubt, specifying DFARS-compliant material adds minimal cost and eliminates compliance risk.