DFARS 252.225-7014: Why It’s Reserved and the Replacement Restriction

DFARS 252.225-7014 is a reserved clause. The Department of Defense removed it in a 2008 rulemaking, and the domestic specialty metals rules it once carried now sit in DFARS 252.225-7009, “Restriction on Acquisition of Certain Articles Containing Specialty Metals,” with the accompanying policy in DFARS 225.7003. If you found a reference to 252.225-7014 in an older contract, compliance manual, or supplier flowdown, the operative language today is in those successor provisions, and the underlying statute at 10 U.S.C. § 4863 continues to carry real teeth.¹

Why the Clause Is Reserved

The clause originally appeared as “Preference for Domestic Specialty Metals” and required contractors to ensure that specialty metals delivered under DoD contracts were melted in the United States. In July 2008, the Defense Acquisition Regulations System published a final rule that removed and reserved 252.225-7014 as part of a broader restructuring of the specialty metals restrictions.² Look up the section on the official DFARS site today and the entry reads “Reserved.”

The replacement, DFARS 252.225-7009, is longer and more structured than the old provision. It carries its own definitions, an itemized list of exceptions, and explicit flowdown language for subcontracts. Everything below describes those current rules.

The Statutory Backbone

The specialty metals restriction is a statutory prohibition, not just a preference. Under 10 U.S.C. § 4863, the DoD is barred from acquiring certain defense items if they contain specialty metals that were not melted or produced in the United States. The covered categories are aircraft, missile and space systems, ships, tank and automotive items, weapon systems, and ammunition, along with their components. The statute also prohibits direct DoD purchases of raw specialty metal stock that was not domestically melted or produced.³

DFARS 252.225-7009 is the contract clause that translates that prohibition into supplier-facing language. DFARS 225.7003 supplies the policy framework, including the detailed exceptions and waiver procedures.

What the Current Restriction Requires

Any specialty metal in items delivered under a covered contract must be melted or produced in the United States, its outlying areas, or a qualifying country. “Melted” refers to conventional smelting and casting. “Produced” covers powder metallurgy processes: atomization, sputtering, and final consolidation of non-melt derived metal powders.⁴

Origin is traced to the earliest processing stage. A titanium forging machined into a bracket in Ohio still fails the test if the titanium sponge was originally melted in a non-qualifying country. The country where the finished part was cut, formed, or assembled does not decide compliance.

Specialty metals themselves are defined categories, not a general term. They include specified high-alloy steels, nickel and iron-nickel alloys, cobalt alloys, titanium and titanium alloys, and zirconium and zirconium alloys, each set out by composition thresholds in the clause.⁴

Which Contracts Are Covered

The restriction reaches DoD contracts for aircraft, missile and space systems, ships, tank and automotive items, weapon systems, ammunition, and their components when those items contain specialty metals. It also applies to direct purchases of raw specialty metal mill products such as bar, billet, slab, wire, plate, sheet, castings, and forgings.⁵

Contracts at or below the simplified acquisition threshold are exempt. That threshold rose to $350,000 in 2025, up from $250,000.⁶ The specialty metals rule is distinct from the Buy American Act. Buy American looks at the country of manufacture of the end product; the specialty metals restriction reaches deeper and tracks where the raw metal was first melted or produced.

Qualifying countries, those with reciprocal defense procurement agreements with the United States, are treated the same as domestic sources for specialty metal origin. Items manufactured in a qualifying country are also excepted under DFARS 225.7003-3.⁷

Exceptions That Come Up Most Often

Most compliance questions turn on the exceptions. Overcompliance means paying more for domestic metal when you don’t have to; undercompliance means delivering noncompliant hardware to the government. The categories are grouped into acquisition-level exemptions and item-level exemptions.

Acquisition-Level Exceptions

Certain acquisitions sit outside the restriction entirely:

Purchases at or below the simplified acquisition threshold.
Acquisitions outside the United States that support combat operations, and acquisitions supporting contingency operations.
Acquisitions where non-competitive procedures were approved due to unusual and compelling urgency.
Commissary resale items.
Items acquired for test and evaluation under the foreign comparative testing program. Follow-on production contracts do not inherit this exception.

Item-Level Exceptions

Even inside a covered contract, individual items may qualify for an exception:

Electronic components are broadly exempt, unless the Secretary of Defense determines that domestic availability of a particular electronic component is critical to national security.
Commercially available off-the-shelf (COTS) items containing specialty metals are generally exempt, with important carve-outs. Raw specialty metal mill products that have not been incorporated into an end item remain restricted. Forgings, castings, and high-performance magnets made of specialty metals are restricted unless incorporated into a COTS end item or subsystem. COTS fasteners are restricted unless incorporated into a COTS assembly or unless they qualify under the fastener exception. When a COTS item is modified with non-standard specialty metal components after acceptance, those added metals must comply.
Commercial fasteners are exempt if the manufacturer certifies that it will purchase domestically melted or produced specialty metal equal to at least 50 percent of the total specialty metal it buys for fastener production during the relevant year.
Items manufactured in a qualifying country, or containing specialty metals melted or produced in a qualifying country.

For COTS end items valued at $5 million or more per item, the acquiring agency must submit an annual report to the Principal Director of Defense Pricing, Contracting, and Acquisition Policy.⁷

Domestic Non-Availability Determinations

When compliant specialty metal of satisfactory quality and sufficient quantity cannot be obtained domestically at a reasonable price, the government can grant a domestic non-availability determination (DNAD). The statute requires a written finding that the needed metal, in the required form, is not available from domestic or qualifying country sources when and where it is needed.³

Approval authority can be delegated, but not to low-level officials. For a single acquisition program, the head of the contracting activity for the relevant component can approve. For multiple programs within one military department, the senior acquisition executive of that department holds the authority. For exceptions crossing more than one military department, authority rests with the Under Secretary of Defense for Acquisition and Sustainment. Contractors cannot self-certify non-availability. If your supply chain cannot source compliant metal, raise the issue with the contracting officer early enough for the government to process the determination before delivery deadlines.

Flowdown to Subcontractors

Prime contractors must flow the specialty metals restriction down to subcontractors at every tier when those subcontracts involve items containing specialty metals. The flowdown is not optional, and it applies to subcontracts for commercial items. When flowing down DFARS 252.225-7009, the contractor inserts the definitions, restriction, and exceptions paragraphs, plus the flowdown paragraph itself. The minimal content exception can be adjusted only as needed to manage compliance at the prime level, and the clause otherwise stays intact beyond identifying the appropriate parties.⁸

This is where compliance gets hard in practice. A prime contractor building an aircraft engine may have dozens of sub-tier suppliers providing castings, forgings, and fasteners. Each one has to trace its specialty metal back to the melt source. If a fourth-tier vendor substitutes non-compliant titanium bar stock because it was cheaper or faster to obtain, the prime is on the hook when the government discovers it.

Documenting Compliance

No single DFARS provision spells out the exact documentation. In practice, contractors maintain traceability through mill test reports, certificates of conformance, and material certifications that identify the country of melt or production. Those records should follow the metal from the mill through each processing step to the finished deliverable, and many prime contractors require sub-tier suppliers to submit certifications before accepting incoming material.

What Happens When Compliance Fails

When a contractor discovers that specialty metals in delivered or in-process hardware do not comply, the situation can escalate fast. Under FAR 52.203-13, contractors holding contracts above $6 million with a performance period of at least 120 days must timely disclose credible evidence of violations of federal criminal law or the civil False Claims Act to the agency’s Office of Inspector General, with a copy to the contracting officer. Disclosures to the DoD Inspector General can be submitted online, by email to cdp@dodig.mil, or by mail.⁹

Specialty metals violations can implicate the False Claims Act if a contractor certified compliance when it knew or should have known the metals were non-compliant. Beyond disclosure obligations, a violation can result in contract termination for default, rejection of delivered hardware, mandatory rework at the contractor’s expense, and in serious cases, suspension or debarment. The financial exposure can dwarf the cost of the non-compliant metal itself, which is why experienced defense contractors treat specialty metals traceability as a core quality function rather than paperwork.

1
Acquisition.GOV. DFARS 252.225-7014 – Reserved
2
Federal Register. Defense Federal Acquisition Regulation Supplement; Restriction on Acquisition of Specialty Metals
3
GovInfo. 10 USC 4863 – Requirement to Buy Strategic Materials Critical to National Security From American Sources; Exceptions
4
Acquisition.GOV. DFARS 252.225-7009 – Restriction on Acquisition of Certain Articles Containing Specialty Metals
5
Acquisition.GOV. DFARS 225.7003-2 – Restrictions
6
Federal Register. Inflation Adjustment of Acquisition-Related Thresholds
7
Acquisition.GOV. DFARS 225.7003-3 – Exceptions
8
Federal Register. Flowdown of Specialty Metals Restrictions (DFARS Case 2014-D011)
9
Department of Defense Office of Inspector General. Contractor Disclosure Program