How to Fill Out and Submit FAA Form 5100-136: Buy American Worksheet

FAA Form 5100-136, the Buy American Project/Product Content Percentage Calculation Worksheet, is what airport sponsors, prime contractors, manufacturers, and suppliers use to show the FAA how much of a product or project was sourced in the United States on an Airport Improvement Program (AIP) grant. You break the product down into components and subcomponents, assign a domestic and non-domestic cost to each line, and the resulting percentage tells the FAA whether the work meets federal domestic-content thresholds or needs a waiver.1Federal Aviation Administration. FAA 5100-136 – Buy American Project/Product Content Percentage Calculation Worksheet

One quick boundary before you start: this is not the AIP performance report. That is Form 5100-140, a separate document that tracks project milestones.2Federal Aviation Administration. Form FAA 5100-140 – Performance Report Form 5100-136 does one job: it produces the domestic-content percentage for Buy American review, and it often travels with Form 5100-137, the Final Assembly Questionnaire.3Federal Aviation Administration. Buy American Preference Requirements

When You Actually Need to File It

Under 49 U.S.C. § 50101, AIP funds may only be obligated when steel and manufactured goods used on the project are produced in the United States.4Office of the Law Revision Counsel. 49 USC 50101 – Buying Goods Produced in the United States Iron and steel must be 100 percent domestic with no partial-content exception. For other manufactured products, one available waiver path allows some foreign content as long as more than 60 percent of total component cost is domestic and final assembly happened in the United States. Form 5100-136 is what produces that number.

You do not need this form if every product on the project already sits on the FAA’s Buy American Conformance List, which catalogs equipment that has received a nationwide waiver. FAA Headquarters (APP-500) maintains that list.3Federal Aviation Administration. Buy American Preference Requirements

The Build America, Buy America Act layered additional requirements on top of § 50101. For projects obligated on or after October 1, 2026, manufactured products permanently incorporated into the project must be manufactured in the U.S. with domestic component costs exceeding 55 percent of total component costs, and the domestic-sourcing rules extend to construction materials such as lumber, drywall, glass, non-ferrous metals, and plastics.5Federal Register. Buy America Requirements for Manufactured Products The current version of the form has a dedicated section for those construction materials.

What to Gather Before You Open the Form

Collect these first, because the worksheet moves quickly once you have them:

  • The FAA Award Number for the AIP grant.
  • The Airport LOCID.
  • Any FAA Certified Equipment Number and the relevant Advisory Circular, if the product is covered by one.
  • Itemized material cost records for every component and subcomponent, split between U.S.-sourced and non-U.S.-sourced. Exclude labor and retail markup.6Federal Aviation Administration. FAA 5100-136 – Buy American Worksheet
  • Country of origin for every non-U.S. material.
  • Documentation of your sourcing efforts if you are seeking a waiver for non-domestic construction materials, including outreach to the Manufacturing Extension Partnership (MEP).

Filling Out the Form, Section by Section

The current version is dated August 2025 and expires December 31, 2026. Check the FAA forms page for a newer release before submitting.

Applicant Information

Enter the date, your name or company name, and mark whether you are a prime contractor, manufacturer, or supplier. Add a point of contact with phone and email, plus the business address. Whoever signs here is on the hook for the accuracy of the numbers below.

Project and Product Information

Fill in the FAA Eligible Project description, the airport sponsor’s name, the Airport LOCID, and the FAA Award Number. Add the FAA Certified Equipment Number and Advisory Circular reference if applicable. Then enter the three cost totals that the material structure worksheet will generate: Total Material Cost, Total U.S. Material Content Cost and Percentage, and Total Non-U.S. Material Content Cost and Percentage.6Federal Aviation Administration. FAA 5100-136 – Buy American Worksheet

BABA Construction Materials

The form asks whether the project includes any iron, steel, or construction materials that are not 100 percent produced in the United States. If yes, list the cost and percentage for each affected category: steel, iron, non-ferrous metals, plastics and polymer-based products, glass (including optic glass), lumber, and drywall.6Federal Aviation Administration. FAA 5100-136 – Buy American Worksheet A justification block asks you to describe your search for a domestic source, including market research and MEP outreach.

The Material Structure Worksheet

This is the core of the form. You break the product or project into three levels:6Federal Aviation Administration. FAA 5100-136 – Buy American Worksheet

  • Level 0 is the finished product or completed project.
  • Level 1 lists the components that complete it. For a building, that means structural steel, windows, elevators, electrical systems, plumbing, and roofing.
  • Level 2 lists subcomponents. If an engine is a Level 1 component of a vehicle, its spark plugs, belts, and fasteners are Level 2.

Materials below Level 2 roll up into their parent line rather than getting their own row. For each line, enter a material reference number, a clear description, quantity, and unit of measure. Do not use “lump sum” or “lot” as a unit. Stick to concrete measures like each, ton, or square foot. Then enter unit cost for non-U.S. material and U.S. material separately. The form calculates total non-U.S. cost, total U.S. cost, and total material cost for each line.

Every cost excludes labor and retail markup. Price multiplied by quantity equals cost. The form’s worked example runs a project with $690,000 in total material costs, of which $535,000 (about 77.5 percent) is domestic and $155,000 (about 22.5 percent) is foreign.6Federal Aviation Administration. FAA 5100-136 – Buy American Worksheet That domestic percentage is what the FAA compares against the threshold.

On any line containing non-U.S. material, record the country from which the majority of that foreign material was sourced. A country abbreviation is the minimum.

Certification

The bottom of the form is a signed certification. The form itself warns that a false certification can violate 18 U.S.C. § 1001 (false statements to a federal agency) and 49 U.S.C. § 47126 (criminal penalties for airport-related fraud).6Federal Aviation Administration. FAA 5100-136 – Buy American Worksheet Sign only if the cost data ties back to your actual procurement records.

Which Waiver Type Your Numbers Support

Four waiver types exist under § 50101, and the percentage the worksheet produces points to one of them:

  • Type I, Public Interest: the Buy American preference would be inconsistent with the public interest. Headquarters approval required.
  • Type II, Nonavailability: the steel or goods are not produced domestically in sufficient quantity or satisfactory quality. Headquarters approval required.
  • Type III, Domestic Content Above 60 Percent: the cost of U.S.-produced components and subcomponents exceeds 60 percent of total component costs, and final assembly occurred in the United States.4Office of the Law Revision Counsel. 49 USC 50101 – Buying Goods Produced in the United States
  • Type IV, Unreasonable Cost: using domestic material would raise overall project cost by more than 25 percent.4Office of the Law Revision Counsel. 49 USC 50101 – Buying Goods Produced in the United States

The 25 percent measure runs against overall project cost. The 60 percent measure runs against components within the specific facility or equipment being procured. Form 5100-136 produces the numbers for both.

Where and How to Submit

Airport sponsors submit Form 5100-136 to their FAA Regional Office or local Airports District Office (ADO).3Federal Aviation Administration. Buy American Preference Requirements Contractors, manufacturers, and suppliers usually hand the completed worksheet to the airport sponsor, who bundles it into the waiver request package sent to the FAA. Call your ADO first to confirm whether they want electronic or hard copy, and whether they expect Form 5100-137 or other supplemental documentation with it.

The FAA does not publish a fixed processing timeline. Build lead time into procurement, especially for Type I and Type II waivers, which require Headquarters-level review rather than regional approval.

Mistakes That Draw Audit Findings

A 2026 DOT Office of Inspector General audit of infrastructure-law-funded FAA contracts flagged patterns worth avoiding, because most tie back to the exact documentation this form exists to produce.7U.S. Department of Transportation – Office of Inspector General. FAA Did Not Adequately Monitor and Enforce IIJA-Funded Contracts Compliance With Buy American Requirements

  • No waiver on file at all. In one case, $2.6 million in foreign-made electrical equipment went into a contract with $26.5 million in infrastructure-law funding, with no waiver documentation.
  • Stale waivers. A contracting officer added $41.1 million in new funding to an existing contract without reassessing an eight-year-old waiver from 2014.
  • Skipped approval steps. A waiver memorandum was signed without completing the required nonavailability determination template or getting legal and OMB review.
  • Missing Buy American clauses in the contract itself, on roughly $272.7 million in federal funds spread across five of nine audited contracts.

The takeaway for anyone completing Form 5100-136: get the waiver before the foreign product is installed, keep the worksheet’s cost data aligned with your procurement records, and refresh the paperwork when the contract is modified. That is what survives an audit.