October 1 Buy America Phase Adds Domestic Component Test for Highway Products

A new phase of federal Buy America requirements applies to manufactured products in covered highway projects obligated on or after October 1, 2026. Under 23 CFR 635.410, qualifying products must be manufactured in the United States and meet a domestic component-cost requirement.

The cost of components mined, produced or manufactured in the United States must be greater than 55 percent of the total component cost. The relevant date is the project’s federal funding obligation, rather than simply when a product is ordered or delivered.

The regulation addresses manufactured products permanently incorporated into the project. Iron and steel are subject to separate provisions, making product classification and the applicable project requirements important parts of purchasing documentation.

Infraday analysis

For owners, contractors and manufacturers, the practical change is a need to establish compliance early enough to inform procurement. Manufacturing location alone may no longer answer the component-content question for affected projects. Teams should align supplier documentation with the applicable obligation date and contract requirements before committing to products with long lead times.

Source: 23 CFR 635.410, current regulation reviewed October 4, 2026.

Featured photograph: Gowanus Expressway in Brooklyn, May 2024. Illustrative highway photograph. Photo: Famartin. CC BY-SA 4.0. Image may be resized or cropped for display.