Background
State DOTs are required to comply with the 2022 Build America, Buy America (BABA) Act, ensuring that federally funded infrastructure projects use domestically produced materials. The Federal Highway Administration announced additional rules impacting state DOTs in 2025:
For projects obligated on or after October 1, 2025, final assembly of all manufactured projects must occur in the U.S.
For projects obligated on or after October 1, 2026, in addition to the final assembly requirement, the cost of components of products that are mined, produced, or manufactured in the U.S. must be greater than 55 percent of the total cost of all components of the manufactured product.
Research
Initial Scope
WTRC members believed that a synthesis research project focused on BABA requirements and the compliance challenges facing western state DOTs could provide valuable insights to improve infrastructure delivery. By examining current practices, the project may identify gaps and issues in implementation and offer solutions to streamline compliance.
A key outcome could be the development of a comprehensive guide to help DOTs navigate BABA rules more effectively and establish best practices for procurement. Identifying commonly unavailable materials could help states coordinate with regional suppliers, explore alternative sourcing strategies, or advocate for targeted federal investments in domestic production.
Discontinuation
This synthesis study ultimately was not initiated. WTRC learned that AASHTO Product Evaluation & Audit Solutions developed a Domestic Materials Self-Certification Form:
This certification is for a manufacturer/supplier to certify materials, or supplies are in compliance with the applicable domestic material content procurement preferences found in the Buy America Act requirements (23 CFR 635.410) and the Build America, Buy America Act (BABA) requirements (2 CFR part 184).
Information on using this form was presented in a series of AASHTO webinars in late 2025, which many WTRC members attended. Given the national efforts in this area, together with states having minimal experience using the Domestic Materials Self-Certification Form to review and assess, WTRC decided to redirect funding to other research activities. The group may choose to revisit this topic at a later date.