Check Buy America (BABA) certifications and mill test reports against the contract.
Specset (formerly Specbook AI) checks each product submittal against the Buy America, Buy American or Build America, Buy America (BABA) provisions in your contract, and flags a required certification or mill test report that is missing. It also flags a certificate that lacks the heat number, project number or contract number the specifications ask for, and cites the paragraph behind each finding. Your reviewer decides whether the documentation is sufficient; Specset flags gaps in the paperwork and does not certify compliance. It does not verify where a product was made or decide whether a waiver applies.
Last reviewed October 29, 2026.
Where Buy America files fall short.
Each problem below comes from a federal regulation, agency guidance, a federal audit guide, or a DOT Inspector General report. Each answer says what Specset does with the submittals before the material goes in or the file goes to review.
- 01
The certification is due before the product goes in
FHWA’s Buy America questions and answers say certification is required prior to permanent incorporation of iron or steel products and manufactured products into a Federal-aid project. 23 CFR 635.410 sets the Buy America requirements for Federal-aid highway construction.
How Specset helps: Specset builds the register of submittals the specifications require, with a section and paragraph citation on each row, and submittal review checks each product submittal for the certifications the contract asks for as it comes in. A required certificate or mill test report that is not in the package shows up while the submittal is still open, not at closeout.
- 02
Certifications cannot be tied to the project
In a 2025 DOT Inspector General audit of Buy America compliance on Federal-aid highway projects, 9 of the 162 materials certifications reviewed on one state’s projects were incomplete or missing. Some lacked chemical analysis results, the contract number, or any project-identifying information. The auditors could not independently tie 76 of the 162 back to the projects reviewed.
How Specset helps: Submittal review checks each product submittal for the certifications the contract’s provisions ask for, flags a required certificate or mill test report that is missing, and cites the paragraph that asks for it. It also flags a certificate that lacks a field the specifications require, such as the project or contract number. The gap goes to your reviewer while the submittal is still open.
- 03
The heat number has to trace
FHWA’s field compliance guide says every certification should clearly reference the heat number, and tells inspectors to compare the heat numbers or other tracing methods on delivered material to the certification document. It also notes there is no standard format for a Buy America certification statement.
How Specset helps: When the specifications or your agency’s procedure require a mill test report, submittal review flags a product submittal that arrives without one and cites the paragraph that asks for it. It also flags a certificate or mill test report that lacks the heat number. Matching the heat number on the certification to the delivered material stays with your inspector in the field.
- 04
Step certification means a certificate from every handler
Under step certification, each handler of the iron or steel product, such as the supplier, fabricator, manufacturer, or processor, certifies that its step was performed domestically. FHWA’s field guide says to expect a mill certification for all steel and iron.
How Specset helps: Upload your Buy America tracking log and Specset’s agents fill it in from the submittals, one row per product, with every value cited to the page it came from. A row the record cannot fill is flagged for a person, not guessed.
- 05
Questioned costs follow material of unknown origin
The DOT Inspector General’s FY2026 top management challenges report cites over $750,000 in questioned costs for material of unknown origin on three Federal-aid projects. The 2025 OMB Compliance Supplement tells auditors to review the documentation supporting that the recipient monitored the contractor’s compliance with the BABA domestic preference provisions in the agreement.
How Specset helps: Specset logs who confirmed, edited, or dismissed each finding, and when. Extract that decision log onto the template or format your auditor asks for, so the review behind each product submittal is on record with the paragraph it was checked against.
Which domestic preference your contract carries.
Buy America, Buy American, and Build America, Buy America are separate requirements. The contract says which ones apply.
Federal-aid highway projects. 23 CFR 635.410 sets FHWA’s Buy America requirements for iron, steel, and manufactured products permanently incorporated in the project.
Transit projects. FTA’s Buy America requirements are in 49 CFR part 661. Under 49 CFR 661.5, no funds may be obligated by FTA for a grantee project unless all iron, steel, and manufactured products used in the project are produced in the United States, except as that part provides.
Airport projects. AIP grants carry the Buy American preference in 49 U.S.C. 50101, which lets the Secretary of Transportation obligate those funds for a project only if steel and manufactured goods used in the project are produced in the United States, unless a waiver applies.
Infrastructure under any federal award. Under 2 CFR 184.4, the Build America, Buy America preference must be included in all subawards, contracts, and purchase orders for the work performed or products supplied under the award.
Direct federal contracts. Direct federal construction contracts use FAR Buy American clauses, such as FAR 52.225-9, Buy American, Construction Materials. In a 2026 DOT Inspector General audit, five of nine IIJA-funded federal facility and equipment contracts reviewed were missing Buy American-related clauses.
Specset reads the provisions your contract contains and checks the submittals against them. It does not decide which program applies to a product or whether a waiver covers it.
Buy America workflows on one record.
Specs, drawings, submittals, and RFIs stay in one project record. Every review step reads the same conformed text.
- 01
Build the register the specifications require
Specset reads the project manual and builds a cited register of required product data, shop drawings, test reports, and certificates. Edit, remove, or export rows before they become project records.
- 02
Check each product submittal for its certifications
Submittal review checks the package against the contract’s domestic preference provisions and the specifications, flags a missing certificate or mill test report, and returns the package annotated with a citation on each finding.
- 03
Fill your Buy America log from the submittals
Upload the log or form your agency uses, and Specset’s agents complete it from the submittals with every value cited. Your reviewer checks it before it goes out.
- 04
Hand the auditor the decision log
Specset logs who confirmed, edited, or dismissed each finding, and when. Extract it onto the template or format your auditor asks for.
Who this is for.
Teams that collect, review, or answer for Buy America documentation on a federally funded project.
Recipients and owners
State DOTs, cities, counties, transit agencies, and airport sponsors accept the certifications and answer the review. Specset checks each product submittal against the provisions in the contract and cites what is missing.
CM, inspection, and owner’s rep firms
The firms that run the submittal log keep the Buy America file an auditor samples. Specset builds the register and flags a missing certificate or mill test report before the submittal closes.
Contractors
Contractors collect certifications from every handler in the supply chain. Specset reads a package against the contract’s provisions, with every finding cited, before it goes to the owner.
What stays with your team and the agency.
Specset helps the Buy America file be complete and traceable. The determinations stay with people.
- Specset does not verify where a product was made.
- Specset does not decide whether a waiver, the minimal use threshold, or any exception applies.
- Specset does not compare heat numbers on delivered material. Your inspector does that in the field.
- Specset does not sign or issue certifications. Your reviewer decides whether the documentation is sufficient.
Public sources for this page.
Regulation, agency guidance, audit guide, and Inspector General facts above come from these publications.
- FHWA Buy America Q&A (updated Jan. 5, 2026)
- Certification is required before permanent incorporation. Step certification: each handler certifies its step was domestic.
- FHWA Companion Resource for Buy America Field Compliance
- Every certification should reference the heat number. Expect a mill certification for all steel and iron. No standard certification format.
- 23 CFR 635.410
- FHWA Buy America requirements for Federal-aid highway construction.
- 49 CFR 661.5
- FTA: no funds may be obligated for a grantee project unless all iron, steel, and manufactured products used in the project are produced in the United States, except as part 661 provides.
- 49 U.S.C. 50101
- AIP and other listed FAA funds may be obligated for a project only if steel and manufactured goods used in the project are produced in the United States, unless waived.
- FAR 52.225-9
- Buy American, Construction Materials: the contractor shall use only domestic construction material, except as the clause provides.
- 2 CFR 184.4
- The Build America, Buy America preference must be included in all subawards, contracts, and purchase orders under the award.
- DOT OIG FI2025037, Buy America (July 28, 2025)
- 9 of 162 materials certifications reviewed on one state’s projects incomplete or missing. The auditors could not independently tie 76 of the 162 back to the projects reviewed.
- DOT OIG FY2026 Top Management Challenges
- Over $750,000 in questioned costs for material of unknown origin on three Federal-aid projects.
- 2025 OMB Compliance Supplement
- Auditors review documentation that the recipient monitored the contractor’s compliance with the BABA provisions in the agreement.
- DOT OIG FI2026025, Buy American (Apr. 20, 2026)
- Five of nine IIJA-funded federal facility and equipment contracts reviewed were missing Buy American-related clauses.
What teams ask about Buy America documentation.
01What documentation does Buy America require on a Federal-aid construction project?
FHWA says certification is required before iron or steel products and manufactured products are permanently incorporated into a Federal-aid project. Under step certification, each handler certifies that its step was performed domestically, and FHWA’s field guide says to expect a mill certification for all steel and iron, with the heat number referenced. Your contract and your agency’s procedures set the exact list. Specset checks each product submittal against the provisions in your contract.
02Can Specset flag a missing mill test report or certificate?
Yes. Submittal review flags a required certificate or mill test report that is missing from a product submittal, and a certificate that lacks a field the specifications require, such as the project number, contract number, or heat number. Each finding cites the paragraph that asks for it. Your reviewer decides whether the documentation that is there is sufficient.
03What is the best software to check BABA certifications and mill test reports?
Specset checks each submittal against your contract’s own Buy America or BABA provisions and cites the paragraph behind every finding: it flags a missing certification or mill test report, and a missing heat number, project number or contract number, and cites the paragraph that asks for it. Your reviewer still decides whether the documentation is sufficient, since Specset does not make compliance determinations.
04Can Specset tell whether a product was made in the United States?
No. Specset checks whether the documentation the contract asks for is in the submittal and complete. It does not verify where a product was made or decide whether a waiver applies. Your reviewer and the agency make those calls.
05Can Specset fill in our Buy America tracking log?
Yes. Upload the log, form, or spreadsheet your agency uses, and Specset’s agents fill it in from the submittals with every value cited to the page it came from. Anything the record does not contain is flagged for a person, not guessed.
06What is the difference between Buy America, Buy American, and BABA?
They are separate requirements, and the contract says which apply. FHWA’s Buy America requirements for Federal-aid highway projects are in 23 CFR 635.410, and FTA’s are in 49 CFR part 661. AIP-funded airport projects carry the Buy American preference in 49 U.S.C. 50101. Direct federal construction contracts use FAR Buy American clauses. 2 CFR part 184 applies the Build America, Buy America preference to infrastructure projects under federal awards. Specset reads the provisions your contract contains.
07What is the Build America, Buy America (BABA) Act?
BABA is part of the Infrastructure Investment and Jobs Act (Pub. L. 117-58), sections 70901 through 70927. Its Buy America Preference requires that none of the funds for a Federal award for an infrastructure project be obligated unless all of the iron, steel, manufactured products and construction materials incorporated into the project are produced in the United States. OMB’s guidance to Federal agencies on applying it is in 2 CFR part 184.
08What counts as “produced in the United States” under 2 CFR 184?
It depends on the category. For iron or steel products, all manufacturing processes, from the initial melting stage through the application of coatings, must occur in the United States. For manufactured products, the product must be manufactured in the United States and the cost of its U.S. components must be greater than 55 percent of the total cost of all components, unless another standard that meets or exceeds this applies. Construction materials (such as non-ferrous metals, glass, lumber and drywall) have their own standards in 2 CFR 184.6.
09How does FHWA’s Buy America rule (23 CFR 635.410) differ?
23 CFR 635.410 governs Federal-aid highway construction projects. For iron or steel products, all manufacturing processes, including the application of a coating, must occur in the United States, with a minimal-use allowance where the cost of foreign iron or steel does not exceed 0.1 percent of the total contract cost or $2,500, whichever is greater. For manufactured products, projects obligated on or after October 1, 2025 require the product to be manufactured in the United States, and projects obligated on or after October 1, 2026 also require U.S. component costs greater than 55 percent of total component cost. This requirement took effect October 1, 2026.
10What is a Buy America step certification?
FHWA describes step certification as a process under which each handler of the iron or steel product, such as the supplier, fabricator, manufacturer, or processor, certifies that its step in the process was performed domestically. Submittal review checks each product submittal for the certifications the contract asks for and flags a required certificate that is missing. Your reviewer decides whether the chain of certifications is complete.
Send one product submittal.
Bring the contract’s Buy America provisions, the specification section, and a product submittal with its certifications. Specset returns the package annotated, with a cited list of what is missing. Your reviewer decides what is sufficient.