A purchase order carrying a DPAS rating of DO-A7 is a federal priority-rated order for a defense electronic or communications equipment program, and receiving one puts you under a legal duty to accept it, schedule it ahead of your unrated commercial work, and pass the same rating down to your own suppliers. The authority comes from the Defense Priorities and Allocations System, administered by the Department of Commerce under the Defense Production Act of 1950. The rules are mandatory, not advisory, and willful non-compliance is a criminal matter.
What the Rating Actually Says
A DPAS rating has two pieces stuck together. The letters at the front — “DO” here — are the priority level. “DX” is the top tier and outranks everything. “DO” is the second tier, but it still outranks every unrated commercial order in your shop.1eCFR. 15 CFR Part 700 – Defense Priorities and Allocations System
The “A7” is a program identification symbol. It tells you the order supports defense electronic and communications equipment programs; radar is a common example. A7 does not add priority on its own. The legal weight sits in the “DO” in front of it.1eCFR. 15 CFR Part 700 – Defense Priorities and Allocations System
Check That the Order Is Properly Rated
No obligation attaches until the order in front of you contains four specific elements. If any are missing, treat it as defective and go back to the customer for a corrected document before doing anything else.
- The complete priority rating and program symbol, shown as “DO-A7.”
- A specific delivery date. “Immediately” or “ASAP” does not count.
- An authorized signature — handwritten on paper, or a digital signature or name on an electronic order — from someone empowered to place rated orders.
- A certification statement that, in substance, identifies the order as rated, certifies it for national defense use, and requires you to follow 15 CFR Part 700.
All four have to be there.2eCFR. 15 CFR 700.12 – Elements of a Rated Order If the same purchase order combines rated and unrated quantities, the rated portion must be clearly separated, and the certification statement has to be modified so it applies only to the rated portion.3eCFR. 15 CFR 700.17 – Use of Rated Orders
The 15-Day Accept-or-Reject Window
The default is acceptance. You must accept a properly placed rated order and fill it regardless of what else is already scheduled.4eCFR. 15 CFR 700.13 – Acceptance and Rejection of Rated Orders A backlog of commercial work is not a reason to refuse.
You have 15 working days from receipt to accept or reject, in writing or electronically. A rejection has to include your reasons within that same 15-day window. Silence is not rejection, and missing the deadline is where a lot of first-time recipients get into trouble.4eCFR. 15 CFR 700.13 – Acceptance and Rejection of Rated Orders
When You May Reject
You may reject if the customer refuses your regular terms of sale or payment, or if the order is for something you don’t supply or a service you don’t perform. Optional rejections can’t be used to discriminate among customers.4eCFR. 15 CFR 700.13 – Acceptance and Rejection of Rated Orders
When You Must Reject
You must reject if you genuinely cannot deliver by the requested date. But rejection does not end the conversation: you have to tell the customer the earliest date you can deliver and offer to accept the order on that revised date. Note the boundary. A scheduling conflict with unrated commercial work is never a lawful reason to reject. If the only thing keeping you from the delivery date is unrated work in the way, the unrated work has to move.4eCFR. 15 CFR 700.13 – Acceptance and Rejection of Rated Orders
You must also reject if accepting the new DO-A7 order would interfere with delivery of a previously accepted DO or DX rated order. Same rule: offer an alternative delivery date.4eCFR. 15 CFR 700.13 – Acceptance and Rejection of Rated Orders
How You Have To Fill It
Priority on the Shop Floor
Once accepted, the DO-A7 order gets production preference over all unrated orders so you can meet the delivery date. If that means delaying commercial work already in production or staged for shipping, the commercial work is delayed.1eCFR. 15 CFR Part 700 – Defense Priorities and Allocations System The DPAS obligation is the legal cover, but explaining the slip to your commercial customers is on you.
Passing the Rating to Your Suppliers
If you need materials, parts, or components to fill the DO-A7 order, the orders you place with your suppliers must themselves be rated DO-A7, with all four required elements — rating, delivery date, authorized signature, certification statement. Your suppliers then do the same with theirs. The rating rides the supply chain all the way down.5eCFR. 15 CFR 700.15 – Extension of Priority Ratings
A phone call telling a supplier this is a rush defense job does not extend the rating. It has to be done formally, in writing, with the required elements. And every supplier in the chain is under the same mandatory acceptance rules you are.
What You Can’t Use the Rating For
DO-A7 is not a universal fast pass. You cannot use it to pull in delivery earlier than you actually need the goods, to order more than you need (except to hit a supplier’s minimum order quantity), or to stockpile ahead of receiving a rated order. It also cannot be used for plant expansion, construction equipment, or production equipment unless the items will be physically incorporated into the rated project.6eCFR. 15 CFR 700.18 – Limitations on Placing Rated Orders Stretching the rating for price leverage or competitive advantage is exactly what draws enforcement.
When Rated Orders Collide
Multiple rated orders competing for the same capacity follow a set order. DX always beats DO. Among DO-rated orders with conflicting delivery schedules, the earliest delivery date wins. If two DO orders share the same delivery date, the one you received first goes first. If they arrived the same day and you can’t fill them all, accept the ones with the earliest delivery dates, reject the rest, and offer alternative delivery dates for what you rejected.4eCFR. 15 CFR 700.13 – Acceptance and Rejection of Rated Orders
Amendments to an Accepted Order
Not every change resets the clock. Minor amendments — a new shipping destination, a small reduction in quantity, a negligible increase, a design tweak before production begins — leave the order alone. But an amendment that significantly changes your production or delivery schedule is treated as a brand-new rated order dated the day you receive it, which sends you back through the 15-day acceptance process.7eCFR. 15 CFR 700.16 – Changes or Cancellations of Priority Ratings and Rated Orders
Records, Audits, and Asking for Help
Keep accurate and complete records of every transaction tied to the rated order for at least three years. The rule does not dictate a system; it does require the records to be detailed enough that an examiner can tell whether each transaction complied.8eCFR. 15 CFR 700.91 – Records and Reports
The Department of Commerce can send representatives to interview employees, inspect books and records at your place of business, and examine property when enforcement calls for it. If more is needed, the Department can issue an administrative subpoena for testimony or documents. These audits happen in practice, often triggered when a prime contractor reports a supplier failing to meet rated-order obligations.1eCFR. 15 CFR Part 700 – Defense Priorities and Allocations System
If you’ve accepted a DO-A7 order and hit a supply or scheduling problem you genuinely can’t solve on your own, you can request Special Priorities Assistance. If the order came from a Delegate Agency such as the Department of Defense, start with your contract administration officer; the Delegate Agency tries first and escalates to Commerce only if it can’t resolve the issue. Otherwise, go directly to the Department of Commerce. Requests use Form BIS-999 from the Bureau of Industry and Security. The need must be urgent, and you must already have made a reasonable effort on your own. Commerce will not use this process to get you a better price, an earlier delivery than you actually need, or a competitive edge.9eCFR. 15 CFR Part 700 Subpart H – Special Priorities Assistance
Penalties
A willful violation — knowingly refusing to accept a rated order, failing to give it priority, or not flowing the rating down — carries a criminal fine of up to $10,000, up to one year in prison, or both.10Office of the Law Revision Counsel. 50 USC 4513 – Penalties
For inadvertent violations, the Department of Commerce typically sends a written notice specifying the corrective action you need to take. If you don’t follow through, the inadvertent violation is reclassified as willful and the criminal penalties come back into play. The government can also seek a court injunction to force compliance, whether the original violation was deliberate or not.1eCFR. 15 CFR Part 700 – Defense Priorities and Allocations System