DFARS Qualifying Countries: Full List and Specialty Metals

Twenty-six nations hold blanket qualifying country status under the Defense Federal Acquisition Regulation Supplement, and Austria holds a narrower case-by-case status. DFARS qualifying countries are nations that have signed a reciprocal defense procurement memorandum of understanding with the United States, and their defense products can compete for Department of Defense contracts without the Buy American Act or Balance of Payments Program price penalties that apply to other foreign offers.¹

The Current List

The 26 nations receiving blanket qualifying country treatment are:

Australia
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
United Kingdom of Great Britain and Northern Ireland

The list can shift when new memoranda are signed or existing agreements expire. DFARS 225.872-1 was last updated in November 2025.²

Austria Is Different

Austria is not on the blanket list. Austrian defense products may be exempted from Buy American and Balance of Payments restrictions, but only on an individual purchase-by-purchase basis, with a contracting officer determining separately for each acquisition whether to treat the Austrian item as a qualifying country end product.² Contractors sourcing from Austria should not plan around the same automatic treatment the 26 listed countries receive.

What Qualifying Status Means at Bid Evaluation

The practical value of the status shows up when DoD compares offers. For supply contracts, DFARS 225.106(b) applies a 50 percent evaluation factor to non-qualifying foreign offers.¹ A $100,000 non-qualifying foreign bid is evaluated as if it were $150,000 against domestic offers.

Qualifying country offers skip that penalty. The government evaluates them “without regard to the restrictions of the Buy American statute or the Balance of Payments Program,”³ which puts allied manufacturers on the same competitive footing as domestic producers. That equal footing is the single biggest reason the status matters.

How Qualifying Components Count Toward Domestic Content

An end product’s classification depends in part on what it is built from. For items not made wholly or predominantly of iron or steel, the combined cost of domestic and qualifying country components must exceed 65 percent of total component cost for deliveries during calendar years 2024 through 2028, rising to 75 percent starting in 2029.⁴ Qualifying country components count the same as domestic ones in that calculation.⁵

Iron and steel items follow a tighter rule. The cost of any iron and steel not produced in the United States or a qualifying country must be less than 5 percent of the cost of all components, and every manufacturing step for the iron or steel (except refinement of steel additives) must take place in the U.S. or a qualifying country.⁵

One default catches contractors regularly: components of unknown origin are treated as foreign.³ A part that actually came from a qualifying source but cannot be documented as such counts against you.

Where Qualifying Status Does Not Help

Qualifying country status does not override the Berry Amendment, codified at 10 U.S.C. 4862. Berry-covered items must be grown, reprocessed, reused, or produced in the United States, and the carve-outs for qualifying countries are narrow.⁶ The covered categories include:

Food acquired for military use
Clothing and textiles, including outerwear, headwear, underwear, footwear, hosiery, handwear, belts, badges, insignia, and materials and components used to make them
Tents, tarpaulins, and covers, including structural components
Natural and synthetic fibers, including cotton, wool, woven silk, synthetic fabric, canvas, and all textile fibers and yarns
Hand and measuring tools
U.S. flags

Two narrow exceptions let qualifying country sources into Berry territory. Para-aramid fibers and yarns manufactured in a qualifying country may be used in synthetic fabric, but only when the fabric becomes a component of something that is not itself a textile product. Chemical warfare protective clothing may be sourced from a qualifying country if the purchase furthers an existing agreement with that country. A general threshold exception applies to acquisitions under $200,000, though not to athletic footwear provided to service members on initial entry.⁷

Outside of Berry items, qualifying country status also does nothing for suppliers in prohibited-source categories: firms owned or controlled by the governments of Iran, North Korea, or Syria; Communist Chinese military companies for items on the U.S. Munitions List or the 600 series of the Commerce Control List; and countries or regions under Treasury sanctions.⁸

Where Qualifying Status Does Help: Specialty Metals

Defense items containing specialty metals must have those metals melted or produced in the United States, its outlying areas, or a qualifying country. A titanium forging melted in Australia or Germany satisfies the rule the same way one melted in Pennsylvania does. Electronic components and commercially available off-the-shelf items are exempt, though standalone specialty metal mill products (bar, billet, slab, wire, plate, sheet) and standalone forgings and castings are still restricted even if they later get incorporated somewhere.⁹

Certifying Country of Origin

Contractors bidding defense work certify origin on the Buy American—Balance of Payments Program Certificate at DFARS 252.225-7000, identifying each end product as domestic, qualifying country, or other foreign. For qualifying country end products, the certificate requires the specific line item number and the country of origin. For other foreign end products, it also asks whether the item exceeds 55 percent domestic content.³

Preparing the certificate honestly means tracing the supply chain down to the component level, contacting sub-suppliers to confirm where each part was manufactured, and keeping written records of their responses. Because unknown-origin components default to foreign, missing documentation hurts even when the underlying sourcing was fine. Solicitations and submissions typically move through the Procurement Integrated Enterprise Environment portal.¹⁰

Getting an origin claim wrong is expensive. Knowingly submitting false information triggers False Claims Act liability, which imposes damages of three times the government’s loss plus per-claim penalties tied to inflation.¹¹ The government can also suspend or debar a contractor from all federal procurement, and debarment runs government-wide.¹²

Prime contractors carry that certification risk down through the supply chain. Under DFARS 252.225-7002, they cannot exclude qualifying country or U.S. sources from competing for subcontracts, and they remain responsible for the accuracy of origin data their subcontractors provide. If a subcontractor delivers components from a non-qualifying source and the prime certifies them as qualifying, the prime absorbs the enforcement consequences.

1
Acquisition.GOV. Part 225 – Foreign Acquisition
2
Acquisition.GOV. 225.872-1 General
3
eCFR. 48 CFR 252.225-7000 – Balance of Payments Program Certificate
4
Acquisition.GOV. Subpart 25.1 – Buy American-Supplies
5
Acquisition.GOV. Buy American and Balance of Payments Program
6
Acquisition.GOV. 225.7002-1 Restrictions
7
Acquisition.GOV. 225.7002-2 Exceptions
8
Acquisition.GOV. Subpart 225.7 – Prohibited Sources
9
Acquisition.GOV. 252.225-7009 Restriction on Acquisition of Certain Articles Containing Specialty Metals
10
Procurement Integrated Enterprise Environment. Procurement Integrated Enterprise Environment
11
Department of Justice. The False Claims Act
12
Acquisition.GOV. Subpart 9.4 – Debarment, Suspension, and Ineligibility