What is the 55% domestic content threshold under BABA?
The 55% domestic content threshold is the share of component cost a manufactured product must be US-origin to pass BABA. Here is the number, why it is not the one that escalates, and the 1 October 2026 date that matters for highway projects.
The 55% domestic content threshold is the line a manufactured product has to clear to count as domestic under Build America, Buy America. Put plainly, more than 55 percent of the product's total component cost has to come from components mined, produced or manufactured in the United States. Miss it and the product is non-compliant on its face, even if it was assembled in an American factory. This guide covers the number itself, the escalating threshold it gets confused with, and the one date in 2026 that genuinely changes who the test applies to.
What the threshold actually measures
The 55 percent is a share of component cost, not of the finished product's price. You take the cost of the US-origin components, divide by the total cost of all components, and compare to 55 percent. Assembly labour, overhead and profit are not components and sit outside the sum. Our guide on how domestic content is calculated walks the arithmetic in full.
The test is greater than 55 percent. A product whose domestic component cost lands at exactly 55.0 percent does not pass, so build the bill of materials with headroom.
It only applies to manufactured products
This is the part teams most often get wrong. The 55 percent threshold is specific to the manufactured-products category. Iron and steel products are judged all-or-nothing, with every manufacturing step required to happen in the United States, and construction materials use their own pass-or-fail standard. Applying a percentage to a steel beam is a category error. Confirm the category first, then reach for the number.
No, the 55 percent is not scheduled to rise
This is the most common piece of misinformation about BABA, and it comes from mixing up two domestic-content regimes that use similar language and different numbers. The Buy American Act, which governs what the federal government buys directly for itself, is on a published escalating schedule. Build America, Buy America, which governs federally-funded infrastructure built by somebody else, sits at greater than 55 percent with no scheduled increase. If you are a contractor on a grant-funded water or highway project, BABA is your regime and 55 percent is your number.
| Regime | Applies to | Domestic content threshold |
|---|---|---|
| Build America, Buy America (BABA) | Federally-funded infrastructure projects (grants, loans, SRF) | Greater than 55%, no scheduled increase |
| Buy American Act (FAR part 25) | Direct federal procurement of supplies | Above 60%, rising to 65% for 2024-2028 and 75% from 2029 |
A manufactured product is produced in the United States if the cost of the components of the product that are mined, produced, or manufactured in the United States is greater than 55 percent of the total cost of all components. (BABA standard, per OMB M-24-02 and 2 CFR 184.3)
What 1 October 2026 actually changes
There is a real date, and it is about WHO the test applies to rather than what the number is. FHWA ran a general waiver from 1983 that exempted manufactured products from Buy America on federal-aid highway projects entirely. A final rule published on 14 January 2025 terminated it and phased the requirement in. Projects obligated on or after 1 October 2025 must have their manufactured products assembled in the United States, with no component-cost test. Projects obligated on or after 1 October 2026 must meet that final assembly requirement and the greater-than-55-percent component-cost test.
So the same traffic signal controller, on the same shelf, is compliant on a highway project obligated in September 2026 and non-compliant on one obligated in October 2026. What governs is the date your federal funds were obligated, not the date you run the check. The threshold matrix shows the phase schedule alongside the standard, read from the same ruleset the calculator uses so the two cannot drift apart.
A quick sanity check
Knowing your percentage precisely beats assuming it, because the test is unforgiving at the line: greater than 55 percent means a product at exactly 55.0 percent fails. Headroom above the number is worth having for the ordinary reason that component costs move between quote and delivery, not because the threshold is going to move. The OMB Made in America Office is the authority on the governing standard.
Check where your bill of materials sits against the 55 percent line, for your agency and your obligation date.
Run the calculatorFrequently asked questions
- What is the 55% domestic content threshold?
- It is the minimum share of a manufactured product's component cost that must be US-origin for the product to count as domestic under BABA. The US component cost must be greater than 55 percent of the total component cost.
- Does the 55 percent threshold apply to iron and steel?
- No. Iron and steel products must have all manufacturing occur in the United States, an all-or-nothing standard with no percentage. The 55 percent test applies only to manufactured products.
- When does the BABA domestic content threshold increase?
- It does not. BABA sits at greater than 55 percent for manufactured products with no scheduled increase. The escalating schedule people are usually thinking of belongs to the Buy American Act, which covers direct federal procurement and rises to 65 percent for 2024 through 2028 and 75 percent from 2029. What changes on 1 October 2026 is that FHWA begins applying the 55 percent test to manufactured products on federal-aid highway projects, having applied a US final assembly test only since 1 October 2025.
- Is exactly 55 percent enough to pass?
- No. The test is greater than 55 percent, so a product at exactly 55.0 percent does not pass. Build in headroom above the line.
This guide is compliance guidance, not legal advice or a binding determination by any funding agency. To see the cited verdict for your own bill of materials, use the free BOM calculator, or see how the same engine works from your own code or an AI agent.
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