A Build America, Buy America (BABA) certification form is a written statement, signed by a manufacturer or supplier, declaring that iron, steel, manufactured products, or construction materials delivered to a federally funded infrastructure project were produced in the United States. There is no single government-wide form. The template you use depends on which federal agency funds the project, and the domestic content standard you certify under depends on what you are supplying.
Find the Right Template for Your Funding Agency
Start by identifying the federal agency behind the grant. The EPA publishes downloadable certification letter templates on its BABA resources page, with separate versions for iron and steel products, manufactured products, and construction materials.1United States Environmental Protection Agency. Build America, Buy America (BABA) Act Resources If your project is funded through a State Revolving Fund or another EPA grant, use those.
FHWA does not prescribe a specific form. It expects manufacturers to provide their own written certifications and leaves the format to the grant recipient.2Federal Register. Buy America Requirements for Manufactured Products Many state DOTs and local project owners have built their own forms or require a letter on company letterhead. If you are supplying a DOT-funded project, ask the prime contractor or project owner for the required format before you draft anything.
HUD, the Department of Energy, USDA, and other agencies each administer BABA certifications through their own grant processes. The award notification or grant agreement will identify the documentation needed. When it isn’t clear, contact the federal program officer named on the award.
Certify Under the Right Domestic Content Standard
Three standards exist, and each material category gets exactly one. Certifying under the wrong standard invalidates the submission.
Iron and Steel
Every manufacturing process must occur in the United States, from initial melting through the application of any coatings.3eCFR. 2 CFR 184.3 – Definitions That includes reheating, refining, rolling, drawing, finishing, fabricating, and coating.4United States Environmental Protection Agency. Certification Letter Template for Iron and Steel Products One overseas step and the product fails. There is no percentage-based exception.
Manufactured Products
Two conditions apply. Final manufacturing must have taken place in the United States, and the cost of domestically produced components must exceed 55 percent of the total cost of all components.5Department of Energy. Build America, Buy America FHWA’s updated Buy America rule confirms the 55 percent threshold applies to projects obligated on or after October 1, 2026.6U.S. Department of Transportation. FHWA Announces Updates to Buy America Requirements to Promote Domestic Manufacturing Final assembly by itself is not enough if the component math doesn’t clear.
Construction Materials
Construction materials follow an all-domestic-processes standard, but the specific processes depend on the material. The regulation lists eight categories, each with its own definition of “produced in the United States”: non-ferrous metals, plastic and polymer-based products, glass, fiber optic cable, optical fiber, lumber, drywall, and engineered wood.7eCFR. 2 CFR 184.6 – Construction Material Standards Non-ferrous metals cover all processes from initial smelting or melting through final shaping, coating, and assembly. Glass runs from batching and melting through annealing, cooling, and cutting. Lumber runs from debarking through treatment and planing. Each of the eight categories has a comparable list, and your certification must confirm that every listed process for your category happened domestically.
What Goes in the Certification Letter
Even where the format is up to you, the required content is largely the same across agencies. The EPA’s iron and steel template is the most detailed reference point.4United States Environmental Protection Agency. Certification Letter Template for Iron and Steel Products
Print the letter on company letterhead. At the top: date, company name, full mailing address. In the subject line, identify the project by name, location, or contract title. The EPA template requires the project description to be “specific and recognizable enough to easily associate it with this particular project.” “Water project” won’t do.
The body is the certification statement itself. For iron and steel, you declare that all manufacturing processes for the listed products occurred in the United States. For manufactured products, you certify that the items meet the 55 percent component cost test and that final manufacturing happened domestically.8United States Environmental Protection Agency. Certification Letter Template for Manufactured Products For construction materials, you certify that the applicable material-specific processes all occurred in the United States.
Below the statement, list every item, product, or material you shipped. Include the Product Service Code (PSC) and North American Industry Classification System (NAICS) code for each item. List the manufacturing locations by city and state. For iron and steel, break this out step by step: initial melting location, bending or cutting locations, and any other steps performed by different producers.
Add a clause committing you to notify the prime contractor immediately if any compliance statement changes after the letter is issued. Sign the letter and include printed name, professional title, email, and phone. USDA guidance says the letter should be signed by “a qualified manufacturer representative.”9USDA. Build America, Buy America FAQs for Manufacturers The signer needs actual knowledge of the product’s manufacturing origin and authority to bind the company.
Records That Have to Back the Letter
The certification itself is short. The records behind it are not. For iron and steel, keep mill test reports or certificates of origin tracing each manufacturing step to a domestic facility. For manufactured products, keep a detailed cost breakdown showing domestic component cost against total component cost and demonstrating the 55 percent threshold is met.
If you are the prime contractor or grant recipient, collect certification letters from every manufacturer and supplier whose materials go into the project. Federal program officers and auditors can request BABA compliance documentation during desk reviews, site visits, and project closeout.10NTIA. Build America, Buy America Compliance and Documentation Organize the file before anyone asks for it.
How and When the Certification Moves
Certifications flow up the supply chain, not straight to the funding agency. A manufacturer sends the letter to the prime contractor. The prime contractor gathers letters from all suppliers and puts them in the project compliance file. The grant recipient makes that file available to the agency on request. Some agencies require the letters to be uploaded to a grant management portal; others accept them as part of bid packages or payment requests.
Get the paperwork in place before materials arrive on site. Agencies generally will not disburse funds for material costs without it, and submitting a certification after an auditor has already flagged a gap is hard to recover from.10NTIA. Build America, Buy America Compliance and Documentation
When BABA Doesn’t Apply
Not every federally funded project triggers a certification. A small-grants waiver exempts infrastructure projects where total federal financial assistance falls at or below the simplified acquisition threshold, recently raised to $350,000.11Federal Register. Inflation Adjustment of Acquisition-Related Thresholds If the federal award is $350,000 or less, BABA certification is not required.
BABA also only applies to “infrastructure projects”: construction, alteration, maintenance, or repair of infrastructure in the United States. Awards funding equipment purchases, research, or non-infrastructure work fall outside it even if they exceed the threshold.
If You Can’t Certify: Waivers
When you cannot meet the domestic content requirements, the funding agency can grant a waiver. There are three types.12HUD Exchange. BABA Waivers
A nonavailability waiver applies when the required materials are not produced domestically in sufficient quantity or satisfactory quality. To support one, you must document due diligence, including the names and contact information of at least three manufacturers, distributors, or suppliers you contacted, along with their responses.13General Services Administration. Build America Buy America Waiver Request Data Collection
An unreasonable cost waiver applies when using domestic materials would raise the overall project cost by more than 25 percent. You need a cost comparison between compliant items and non-domestic alternatives, plus an architect or engineer certification for the additional administrative costs of compliance.14United States Environmental Protection Agency. Build America, Buy America (BABA) Act Waivers Open for Public Comment
A public interest waiver applies when the domestic preference would not serve the public interest. It requires an explanation of why waiving the requirement benefits the public for the specific project or product.
Proposed waivers go through a public comment period of at least 15 days, then to the Office of Management and Budget’s Made in America Office for review. Waivers must be approved before non-compliant materials are purchased.10NTIA. Build America, Buy America Compliance and Documentation
What Happens if the Certification Is False
Signing a BABA certification you know to be false is a federal crime. Under 18 U.S.C. § 1001, anyone who knowingly makes a materially false statement in a matter within federal jurisdiction faces up to five years in prison, a fine, or both.15Office of the Law Revision Counsel. 18 USC 1001 – Statements or Entries Generally That reaches the individual who signs, not just the company.
On the civil side, the False Claims Act creates liability for anyone who submits a false claim for payment to the federal government. Following the most recent inflation adjustment, penalties run from $14,308 to $28,618 per false claim, plus treble damages on the amount the government overpaid.16Federal Register. Civil Monetary Penalty Inflation Adjustment A single project with multiple non-compliant shipments can generate multiple violations, and the totals climb fast.