FHWA 55% test October 1, 2026 deadline — every manufactured product on federally assisted highway projects

The most rigorous BABA domestic-content qualification file a manufacturer can get.

DomesticProof assembles an audit-ready domestic-content determination file — component-cost analysis, supplier evidence, signed certification letter, and annual monitoring — checked against the letter of the Build America, Buy America Act and FHWA rules before a senior expert releases it.

Every applicable BABA & FHWA ruleComponent-cost analysis against 55% testSupplier origin evidence collection & validationSenior expert review & signature on every file10-business-day SLA
Why certifications fail

A single missing cost breakdown can void the entire sale.

A manufacturer's domestic-content certification is only as strong as the evidence file behind it. Miss a component cost, skip a supplier origin attestation, misapply the 55% test, or fail to document final assembly — and the certification becomes a False Claims Act exposure event with per-claim penalties of $14,308–$28,619, treble damages, and potential criminal indictment.

Most manufacturers produce certification letters by hand, from memory, under sales pressure. The BOM has not been cost-analyzed since the product was designed. That is exactly where compliance gaps hide.

DomesticProof exists to close that gap with a single, exhaustive standard applied identically to every product family.

1 of 5
certification letters lack a defensible cost analysis behind them
The benchmark

Measured against the letter of the statute — rule by rule.

We do not summarize the law and hope. Every file is scored against a versioned rule pack tied to the exact text of BABA, FHWA final rule, and applicable agency guidance. These are the provisions each file is held to.

BABA §70914

Domestic-content preference

All iron, steel, manufactured products, and construction materials used in infrastructure projects must be produced in the US, with cost-of-components test for manufactured products.

FHWA Final Rule (Jan 2025)

55% component-cost test

For projects obligated on or after October 1, 2026, at least 55% of the cost of all components of a manufactured product must be mined, produced, or manufactured in the US.

FHWA Final Rule (Jan 2025)

Final assembly requirement

For projects obligated on or after October 1, 2025, final assembly of manufactured products must occur in the US.

2 CFR §200.322

Agency certification templates

Grantees must obtain and retain manufacturer certifications in the form specified by the funding agency (EPA, FEMA, DOT, etc.).

31 U.S.C. §3729

False Claims Act liability

False or fraudulent certification of domestic content exposes the signer to treble damages and per-claim penalties; criminal indictments now issued for false sourcing certifications.

Executive Order (Mar 2026)

Made-in-America scrutiny

Tightens waiver standards and requires enhanced documentation for any claim of domestic content under federal assistance programs.

How a file is built

Intake to senior expert release, with deterministic gates the AI cannot overrule.

AI extracts and drafts. Deterministic rules — running as code, outside the model — decide what is complete. A senior domestic-content expert reviews and signs every release. That order is never reversed.

01

Product Gap Scan

Upload the bill of materials and product specs. We return a free completeness read: which cost elements, supplier evidence, and assembly determinations you already have, and which are missing.

02

Evidence & supplier collection

As your authorized clerical agent, we collect country-of-origin attestations from every component supplier, validate them against available documentation, and build the evidence index.

03

Grounded cost analysis

The component-cost workbook is built from your BOM and supplier data, applying the 55% test deterministically — no legal opinions, no invented facts.

04

Deterministic completeness gates

Cost percentages reconcile to the penny; final assembly location is verified; supplier evidence is resolved; agency template formatting is checked. Any failure blocks release.

05

Senior expert release

A senior domestic-content expert reviews the exception queue and signs the determination memo. High-value or complex products route to additional attorney review if needed.

06

Delivery

You receive the file: cost-analysis workbook, determination memo, evidence index, agency-formatted certification letter set, and annual monitoring subscription — ready for your officer to sign and submit.

The bar we hold

Rigor you can measure.

100%
Senior-expert-reviewed
No file ships without a human signature.
10 days
Standard SLA
From complete intake to released file.
<1%
Critical-defect target
Tracked against a gold-standard file library.
4
Evidence-source types
Supplier attestations, BOM cost data, assembly documentation, agency templates — every applicable file.
Why DomesticProof

Built to be the most thorough option a manufacturer has.

Documentation-complete, by design

The deliverable is completeness itself — every cost element, supplier evidence, and rule requirement accounted for or explicitly exception-coded. Nothing is left implicit.

Deterministic, not vibes

The gates that decide completeness are code, not a model's opinion. A cost error cannot slip past a statutory threshold.

In its lane, on purpose

We prepare documentation and run evidence collection as your clerical agent. We never provide legal advice, sign the certification on your behalf, or guarantee outcomes.

Engagement

Flat fee, per product family. No contingency, ever.

Simple, predictable, and aligned with a documentation standard — not a percentage of any contract.

  • A free Product Gap Scan before you commit — see exactly what is missing.
  • One flat fee per released qualification file; disclosed pass-through evidence collection costs.
  • Optional fixed-fee attorney review for complex or high-value product families.
  • Optional annual monitoring subscription for re-verification when BOMs, suppliers, or rules change.
FAQ

Questions, answered precisely.

Is DomesticProof a law firm?
No. DomesticProof, a service of Your Deputy, Obuke LLC, provides documentation-completeness services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. Attorney review is available and recommended for complex or high-value matters.
Do you sign the certification letter for us?
No. The manufacturer's officer signs the certification letter. We provide the evidence file and determination memo that make the signature defensible. The manufacturer remains the certifying party.
What makes a file 'complete'?
Completeness is defined by the applicable rules: the 55% component-cost test verified, final assembly documented, supplier evidence collected and validated, agency template formatting matched, and all assumptions exception-coded. Deterministic gates enforce each one before release.
How fast is it?
The standard SLA is 10 business days from complete intake to a senior-expert-released file. The free Gap Scan is returned much sooner and tells you exactly what is still needed.
How are you priced?
A flat fee per released product family, plus disclosed pass-through evidence collection costs. No contingency and no percentage of any contract or sale proceeds.

See what's missing before it costs you a contract.

Start with a free Product Gap Scan. Send your bill of materials and product specs and we'll return a completeness read against every applicable BABA and FHWA rule.

Documentation-completeness service · not legal advice · the manufacturer signs every certification.