DFARS compliant material: what it means on a mill cert.

This is a working guide for shop quality staff, not legal advice. The DFARS text quoted here was checked on acquisition.gov on October 30, 2026 (DFARS Change 5/7/2026). Your contract, your customer's flowdowns and the contracting officer decide what applies to a given job.

What does "DFARS compliant" mean on a material cert?

On a material cert, "DFARS compliant" almost always means the specialty metals restriction: the mill states that the metal was melted or produced in the US or a qualifying country. DFARS itself is the Defense Federal Acquisition Regulation Supplement, the Department of Defense's additions to the FAR, and it has hundreds of clauses. Only two are about metal sourcing:

• DFARS 252.225-7009, Restriction on Acquisition of Certain Articles Containing Specialty Metals. This is the one that reaches a job shop. It covers aircraft, missile and space systems, ships, tank and automotive items, weapon systems and ammunition, and their components, at any tier.
• DFARS 252.225-7008, Restriction on Acquisition of Specialty Metals. This covers specialty metal delivered to DoD as an end item: the raw stock, casting or forging itself.

Both implement 10 U.S.C. 4863, which was 10 U.S.C. 2533b before the FY2021 National Defense Authorization Act renumbered that part of Title 10. Older POs and certs still say 2533b. Some still cite DFARS 252.225-7014, a clause that was removed around 2009 and is now marked reserved; 7008 and 7009 replaced it. A cert citing 7014 isn't proof of anything by itself. Read what it says about the melt.

For a machine shop: if 252.225-7009 is flowed down to you, every specialty metal in the part you ship must trace to a compliant melt, unless an exception covers it.

Which metals count as DFARS specialty metals?

DFARS 252.225-7009 defines four groups of specialty metal: certain steels, high-alloy nickel and cobalt alloys, titanium and its alloys, and zirconium and its alloys. Paraphrased from the clause:

Not on the list: aluminum alloys, copper alloys (brass, bronze, beryllium copper), magnesium, and plastics. A customer can still add its own sourcing rule for those in the PO, so read the quality clauses, but that isn't the DFARS specialty metals restriction.

Two edge cases to ask your customer about rather than decide alone. A plain carbon steel whose cert shows a residual element close to 0.25%, and an extra-low-carbon stainless whose reported carbon is below 0.02%, which falls outside the clause's definition of steel. Most primes treat every stainless as a specialty metal, and so should you until someone tells you otherwise in writing.

What does "melted or produced" mean?

"Melted or produced" means where the metal was made into alloy, not where it was rolled, cut, sold or shipped from. The clause defines produce as atomization, sputtering, or final consolidation of non-melt-derived metal powders, which covers powder metallurgy and additive feedstock. Melted isn't defined in the clause, so use its plain meaning: the furnace where the heat was poured.

That is why "Country of origin: USA" on a distributor's paperwork isn't enough. A bar melted in a non-qualifying country and finished in the US can carry a US origin and still fail. You need the melt location, tied to the heat number.

Many aerospace alloys are melted more than once (VIM then VAR, or AOD then ESR). The clause doesn't spell out which melt counts. Good mill certs list each melt step and where it was done. If two steps are in different countries, ask your customer how they want it treated before you machine the bar.

Which countries are DFARS qualifying countries?

DFARS 225.003 lists 28 qualifying countries. Most are countries with a reciprocal defense procurement agreement with the US. 27 appear in DFARS 225.872-1(a), and Austria is handled purchase by purchase under 225.872-1(b). Metal melted or produced in any of them meets the specialty metals rule, as does metal melted in the US or its outlying areas (Puerto Rico and Guam, for example).

Countries shops often assume are on the list and aren't: China, India, South Korea, Taiwan, Mexico, Brazil, Ireland, Hungary, Romania and Slovakia. EU or NATO membership is not the test. Neither is the FAR's list of Trade Agreements Act "designated countries", which is a different list for a different rule; South Korea is a designated country under the TAA but not a DFARS qualifying country.

The list changes when DoD concludes a new agreement, and several countries have been added over the past decade. Check DFARS 225.003 on acquisition.gov when you set up a new supplier, and put the date you checked in your supplier file.

What are the exceptions to the specialty metals rule?

The clause lists six exceptions in 252.225-7009(c), and DFARS 225.7003-3 adds whole acquisitions that are exempt. Most of them are decided above the job shop. Here's how each one tends to land on a shop making parts to print:

The practical rule: if the clause is flowed to you, buy compliant metal and keep the proof. Don't claim an exception unless your customer confirms it in writing.

Is DFARS 252.225-7009 the same as Buy American or DFARS 7012?

No. Three different DFARS clauses get called "DFARS compliance", and two of them share the number 7012. They ask different questions and need different evidence:

If a customer survey asks "Are you DFARS compliant?", ask which clause. 252.204-7012 is an IT and CMMC question, not a receiving one.

What should a DFARS compliant mill cert show?

A DFARS compliant mill cert should tie a named melt location to a heat number, and state compliance with the specialty metals clause. Check these on receipt, alongside the usual chemistry and mechanicals covered in certificate of conformance vs material cert:

1. Melt country (and melt facility), for each melt step. Not just "country of origin".
2. Heat number that matches the bar tag and the distributor's paperwork.
3. A DFARS statement that names the clause or describes the rule: "melted in the USA or a qualifying country per DFARS 252.225-7009", or similar wording. "DFARS compliant" alone is weak if the melt country is missing.
4. Material spec and condition matching the drawing, so the statement applies to the material you actually need.
5. Distributor CoC that carries the heat through to your PO, and repeats the DFARS statement if your PO asked for it.

Red flags: a melt country not on the list; a melt country that's blank; a "DFARS" line on the distributor's CoC that the mill cert doesn't support; or a cert that cites only 252.225-7014. Any of these is a hold at receiving, not a note for later.

Worked example: a 17-4PH bar melted in a qualifying country

A shop buys 1.000 in. diameter 17-4PH bar for a bracket on an aircraft program. The PO flows down DFARS 252.225-7009. Here's a mill cert, condensed. The companies, heat and cert numbers are invented, and the values are illustrative only. Check real values against the spec revision your drawing calls.

MILL TEST CERTIFICATE (EN 10204 3.1)            Cert No. NS-24-81733
Nordstal Specialty AB, Sweden

Material:   17-4PH (UNS S17400) bar, Condition A
Spec:       AMS5643, per PO
Size:       1.000 in. round, cold finished, centerless ground
Heat No.:   N52817
Melt:       EAF + AOD, Nordstal, Sweden; remelt ESR, Nordstal, Sweden

Chemistry (wt %, heat analysis)
 C 0.04   Mn 0.55  Si 0.40  P 0.020  S 0.004
 Cr 15.6  Ni 4.4   Cu 3.3   Nb 0.28

Mechanical (Condition A, as required by spec): see attached

DFARS: Material melted in Sweden, a qualifying country per DFARS
225.003, and conforms to DFARS 252.225-7009.

Validated: ____________  Quality Inspector (independent of production)

Read it in four steps:

1. Is it a specialty metal? Yes. Carbon at 0.04% makes it a steel under the clause's definition (0.02 to 2%). Chromium at 15.6% and nickel at 4.4% are far over 0.25%, and copper at 3.3% is over 0.60%. Any one of those is enough.
2. Where was it melted? Sweden, for both the primary melt and the ESR remelt. Sweden is on the DFARS 225.003 list, so the melt is compliant. Had the ESR been done in a non-qualifying country, you'd ask the customer before using it.
3. Does the statement match the facts? The DFARS line names the country and the clause, and the melt line above it agrees. That's the strong form. A bare "DFARS compliant" with no melt line would need a follow-up.
4. Does it trace to your bar? Heat N52817 on the cert, on the bar tag, on the distributor's CoC with your PO number, and written on the traveler at saw cut.

Then the material line on AS9102 Form 2. AS9102 has no DFARS column, so the evidence goes in the spec, cert and comments fields:

Put the melt country in column 13 even though the cert shows it. The reviewer sees the DFARS answer without opening the cert.

How do you flow DFARS specialty metals down to suppliers?

Flow 252.225-7009 down by putting the requirement on every PO for material, and every PO for a part or assembly that contains specialty metal, whenever your customer's PO carries it. The clause itself says paragraphs (a) through (c) and (e)(2) go into subcontracts for items containing specialty metals, including commercial products, and that paragraph (c)(6), the 2% exception, may be modified only as the prime needs to manage it. In practice:

• On the material PO, cite DFARS 252.225-7009 and ask for a mill cert showing melt country and heat, with a DFARS statement. Say that a cert without the melt country will be rejected.
• On subcontract machining POs where the supplier provides material, flow the same clause. For processors who only heat treat or plate, check whether your customer's flowdowns still require it.
• For purchased hardware, ask the fastener supplier for the (c)(3) commercial fastener certification, or for compliant melt certs.
• At receiving, check the melt country against the qualifying list before the material goes to stock. Segregate or tag DFARS material so a non-compliant heat can't be pulled for a DFARS job.
• If something is wrong, stop and tell your customer in writing. Only DoD can grant a nonavailability determination or waiver.

Your AS9100 auditor will look at the same chain under clause 8.4: the requirement on the PO, the evidence on receipt, and the trace to the part. The AS9100 audit checklist for FAI records covers what they sample.

Where software helps

Software can keep the evidence in one place; it can't tell you a melt is compliant. In Deburr, Form 2 lines sit with the ballooned drawing and Form 3 on the FAI, so the material spec, the mill cert number and a comment like "melted in Sweden, DFARS 252.225-7009" stay attached to the report a preparer and an approver sign. You still read the cert and check the country against the list. Start by ballooning a drawing with the free ballooner, or download a blank Form 2 from the free AS9102 templates.

Related: Certificate of conformance vs material cert · AS9102 Form 2 explained · Why FAI reports get rejected · Full vs partial FAI

FAQ

What does DFARS compliant mean on a material cert?

On a material cert, DFARS compliant almost always refers to the specialty metals restriction in DFARS 252.225-7009 (and 252.225-7008 for raw stock delivered as an end item). It means the mill states that the specialty metal was melted or produced in the United States, a US outlying area, or one of the qualifying countries listed in DFARS 225.003. A useful cert also names the melt country and the heat.

Is aluminum a DFARS specialty metal?

No. The DFARS definition of specialty metal covers certain steels, nickel and iron-nickel alloys and cobalt alloys with more than 10 percent of other alloying metals, titanium and titanium alloys, and zirconium and zirconium alloys. Aluminum alloys such as 6061 and 7075 are not on the list, although a customer's purchase order can still impose its own sourcing requirement.

Which countries are DFARS qualifying countries?

As of DFARS Change 5/7/2026, DFARS 225.003 lists 28 qualifying countries: Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Germany, Greece, Israel, Italy, Japan, Latvia, Lithuania, Luxembourg, Netherlands, Norway, Poland, Portugal, Slovenia, Spain, Sweden, Switzerland, Turkey and the United Kingdom. China, India, South Korea, Taiwan and Mexico are not on the list.

Is DFARS 252.204-7012 the same as DFARS compliant material?

No. DFARS 252.204-7012 is the cybersecurity clause for safeguarding covered defense information, built on NIST SP 800-171 and 72-hour incident reporting. It has nothing to do with where metal was melted. Material compliance on a mill cert is DFARS 252.225-7009 or 252.225-7008, the specialty metals clauses.

Can a job shop use the 2 percent minimal content exception?

Usually not on its own. The 2 percent exception in DFARS 252.225-7009(c)(6) is measured against the total specialty metal weight in the end item, estimated in good faith by the contractor, and the clause lets the prime modify that paragraph in subcontracts so the prime can manage it. A machined part is rarely the whole end item, so ask your customer in writing before relying on it.

Sources

1. DFARS 252.225-7009, Restriction on Acquisition of Certain Articles Containing Specialty Metals, acquisition.gov
2. DFARS 225.003 Definitions (qualifying country), acquisition.gov
3. DFARS 225.872-1, Contracting with qualifying country sources: general, acquisition.gov
4. DFARS 225.7003-2, Specialty metals restrictions (implements 10 U.S.C. 4863), acquisition.gov
5. DFARS 225.7003-3, Specialty metals exceptions, acquisition.gov
6. DFARS 252.225-7001, Buy American and Balance of Payments Program, acquisition.gov
7. DFARS 252.204-7012, Safeguarding Covered Defense Information and Cyber Incident Reporting, acquisition.gov
8. Reciprocal Defense Procurement Memoranda of Understanding, DoD Defense Pricing and Contracting