Blogpost

Building with Confidence: What Local Agencies Need to Know About BABAA Compliance

3.7 minute read

December 23, 2025

Federal dollars are powering a new wave of local infrastructure investment—from libraries and community centers to water, roadway, and transit developments. With this funding comes a higher bar for transparency and domestic sourcing under the Build America, Buy America Act (BABAA). For municipal leaders, the key question isn’t “Does BABAA apply?” so much as “How can we deliver our projects on time and on budget—while proving every nut, bolt, and beam complies?”

Understanding BABAA

Passed as part of the Infrastructure Investment and Jobs Act (IIJA) in 2021, BABAA mandates that iron, steel, manufactured products, and construction materials used in federally funded infrastructure projects must be produced in the United States. To qualify as “U.S. made,” a product must contain a defined percentage of domestic content—thresholds that vary by material type and increase over time. As of 2025, at least 55% of a manufactured product’s components must be U.S.-made, rising to 75% by 2029.

In Plain English

Iron + Steel: Every manufacturing process—from melting to coating—must occur in the U.S.
Construction Materials: Items such as glass, cement, lumber, gypsum board, nonferrous metals, and polymer-based materials must be produced domestically.
Manufactured Products: Must contain at least 55% U.S. content by 2025, increasing to 75% by 2026.

Why BABAA Matters

BABAA is as much a documentation and verification challenge as it is a sourcing requirement. Even when the right materials are used, inadequate proof can jeopardize funding or delay closeout.

Key risks include:

Schedule delays tied to limited availability of compliant materials
Higher bid prices as contractors account for uncertainty
Mid-project substitutions when materials cannot be verified
Closeout delays if documentation is incomplete

In other words: If you can’t prove it, it didn’t happen. The documentation is just as important as the materials themselves.

Common Pitfalls and How to Avoid Them

BABAA compliance can feel overwhelming, especially on fast-paced capital programs. The good news? Most challenges are predictable—and preventable—with the right structure and communication. Here are the issues we see most often and how agencies can stay ahead of them:

Vague Bid Documents - Set clear expectations. Spell out exactly what compliance documentation is required—such as mill test reports, manufacturer letters, or domestic content certifications—and when contractors must submit them.
Late Supplier Engagement - Don’t wait until procurement is underway. Identify high-risk or long-lead materials early and confirm that manufacturers can meet BABAA requirements before bids go out.
Fragmented Tracking - Avoid scattered spreadsheets. Use a centralized Materials Compliance Log tied to your CM software to keep data consistent, accessible, and audit ready.
Assuming Waivers - Waivers are the exception, not the plan. Build schedules around domestic sourcing and thoroughly document due diligence if a waiver request becomes unavoidable.
Closeout Surprises - Make compliance continuous—not a final hurdle. Tie pay applications and submittal approvals to complete documentation throughout the job.

Best Practices for Local Agencies

Strong compliance isn’t about doing more—it’s about doing the right things early and consistently. The following practices help agencies streamline verification, reduce risk, and improve contractor accountability from day one:

Set the Rules Early -Integrate BABAA requirements into solicitation documents and ask bidders to identify sensitive materials upfront, along with their sourcing strategies.
Front-Load Sourcing -Hold a materials risk workshop during preconstruction to flag long-lead or hard-to-source items. Provide a pre-submittal checklist that distinguishes iron/steel, construction materials, and manufactured products.
Build a Real Tracking System - Formalize how material compliance will be tracked and reported. Incorporate weekly contractor updates and periodic CM spot audits to maintain transparency.
Integrate Compliance into Controls - Link payments and submittal approvals to complete documentation. This approach improves accountability and helps ensure a smoother project closeout.

The Harris Approach: Compliance with Confidence

Navigating BABAA requires both technical expertise and strategic coordination. Harris’ Construction and Program Management teams help agencies integrate compliance into every project phase—from procurement through closeout.

We help clients:

Standardize compliance documentation
Identify sourcing risks early
Maintain audit readiness
Streamline coordination across disciplines

The result: federally compliant, community-centered infrastructure delivered on time and on budget.

Moving Forward

BABAA represents a long-term shift toward stronger domestic sourcing and documentation requirements in infrastructure delivery. By embedding compliance practices early, local leaders can protect funding, reduce risk, and deliver projects that reflect resilience, transparency, and community value.

At Harris, we help agencies build with confidence—ensuring that every federally funded project is not only compliant, but also a model of innovation and accountability