Introduction

The Federal Highway Administration's Build America, Buy America (BABA) initiative introduces updated requirements for manufactured products used in highway and bridge construction. These changes are part of a broader regulatory shift aimed at increasing transparency, reshaping supply chain strategies, and reinforcing domestic manufacturing within federal infrastructure investments.

TraffiCalm and BABA

At TraffiCalm, our mission is simple: develop and deploy effective technologies that save lives on our roadways. As part of that commitment, we've consistently prioritized domestic manufacturing practices that align with emerging regulatory standards.

The Federal Highway Administration's BABA requirements are reshaping how transportation products are sourced and approved for federally funded projects. These changes represent a national effort to increase transparency, strengthen domestic supply chains, and ensure that infrastructure investments support sustainable production.

Our Radar Speed Signs, Flashing Sign Systems, and Intelligent Warning Systems are manufactured domestically, helping customers meet compliance standards while supporting the broader goals of supply chain resilience. When agencies choose TraffiCalm, they're selecting solutions that are engineered, assembled, and documented with regulatory compliance and public safety in mind.

Implementation Timeline

The BABA requirements will be phased in this year:

• March 17, 2025: Effective Date
• All federally funded projects must ensure proper product classification and compliance with existing Buy America rules for iron and steel.
• October 1, 2025: Final Assembly in the U.S.
• Manufactured products must be assembled in the United States. This concludes a general waiver that previously allowed foreign-assembled products in certain cases.
• October 1, 2026: 55% Domestic Content Requirement
• Products must include components where more than 55% of the total cost is derived from U.S.-mined, produced, or manufactured materials.

Does This Apply to Me?

If you're involved in federally funded infrastructure projects in the United States, then yes, BABA likely applies to you.

The Build America, Buy America Act was enacted as part of the 2021 Infrastructure Investment and Jobs Act (IIJA). It requires that specific product categories, including iron, steel, manufactured products, and construction materials used in federally funded infrastructure, be sourced domestically.

BABA compliance is required for:

• Federal agencies, such as the Federal Highway Administration (FHWA)
• State DOTs and local governments receiving federal funds
• Contractors, integrators, and manufacturers supplying to those federally funded projects

However, BABA does not apply to every project. It only applies when federal funds are involved. If your project is entirely state or privately funded, BABA may not apply, but always confirm with your funding agency.

Understanding Waivers and Exceptions:

In some cases, exceptions may be granted, but they are narrowly defined:

• The waiver must serve the public interest, or
• The required materials are not reasonably available in the U.S., or
• Using domestic materials would increase overall project cost by more than 25%

All waivers must be:

• Product-specific
• Time-limited
• Justified and publicly posted

If you're unsure about your compliance obligations, it's essential to review funding sources, consult with your agency or DOT, and work with vendors who understand the documentation requirements.

Defining Manufactured Products

Per 23 CFR 635.410, manufactured products are items that have been substantially transformed from their original state. If a product qualifies as both manufactured and iron/steel, it must meet all applicable standards under both categories.

End of Blanket Waivers

One of the more impactful changes is the removal of the Manufactured Products General Waiver. Moving forward, any exceptions must be product-specific, time-limited, and supported by thorough justification. This change is expected to significantly narrow the range of products eligible for non-domestic sourcing within federally funded projects.

Industry Impact and Considerations

These policy changes will affect organizations across the transportation ecosystem:

• Manufacturers will need to evaluate supply chains, relocate assembly operations if necessary, and update product documentation to meet new thresholds.
• State DOTs and local agencies may need to revise approved product lists, update procurement workflows, and potentially face reduced vendor options during the transition period.
• Distributors and integrators should prepare for adjustments in product availability, lead times, and compliance documentation requirements.

Practical Next Steps for Agencies and Project Teams

To prepare for these changes, consider the following actions:

1. Conduct Supply Chain Audits: Inventory current products and assess their compliance status under the new requirements.
2. Evaluate Vendor Partnerships: Work with suppliers who can provide clear documentation and demonstrate concrete plans for meeting compliance deadlines.
3. Stay Current on Guidance: Monitor updates from FHWA and your state DOT for ongoing clarifications and implementation details.
4. Develop Internal Tracking Systems: Create processes to verify and document product sourcing, assembly locations, and component origins.
5. Plan for Transition Periods: Consider potential impacts on project timelines and budget allocations as the industry adapts.

Conclusion

The Build America, Buy America requirements represent a significant shift in procurement standards for infrastructure projects. While this brings operational changes and new documentation requirements, it also creates opportunities to build more transparent and resilient supply chains across the transportation sector.

At TraffiCalm, we're committed to supporting agencies and project teams as they navigate this transition. Whether you're working through compliance questions or planning future projects, we're here to provide the documentation, guidance, and reliable safety solutions you need to move forward with confidence.

Understanding these requirements early and building relationships with compliant suppliers will be key to successful project delivery in this evolving regulatory landscape.