The Build America, Buy America Act (BABA) establishes domestic sourcing requirements for materials used in federally funded infrastructure projects, impacting manufacturers, suppliers, contractors, and municipalities across the United States.
On May 14, 2022, the Build America, Buy America (BABA) Act took effect, requiring federal infrastructure projects to use U.S.-produced materials. The law requires that iron and steel be produced in the United States and that manufactured products meet domestic content thresholds, which are currently set at 55% of component costs originating from U.S. sources. Oversight of this law is handled by the Made in America Office (MIAO). Several major updates introduce key compliance deadlines in 2025 and 2026.
Several important regulatory changes affecting manufacturers, equipment suppliers, and infrastructure stakeholders will take effect between 2025 and 2026.
As of March 17, 2025, the Federal Highway Administration and the Environmental Protection Agency have rescinded the longstanding BABA manufactured products general waiver. All federally funded projects must now fully comply.
BABA implementation will occur through a phased timeline that gradually increases domestic manufacturing requirements.
These requirements affect water treatment, wastewater treatment, transportation infrastructure, and public utilities. BABA applies to all federally funded infrastructure projects.
General waivers and exemptions for manufactured products have been rescinded and are now only available in strict, exceptional cases.
The EPA and other federal agencies continue to update compliance documentation, forms, and expectations through 2025-26. Recipients and contractors must provide and maintain up-to-date documentation demonstrating adherence to all BABA requirements.
Below is a summary addressing questions about the BABA act.
The Build America, Buy America Act requires that materials used in federally funded infrastructure projects be produced in the United States unless a waiver is granted.
According to the EPA, “None of the funds made available for a Federal financial assistance program for infrastructure…may be obligated for a project unless all of the iron, steel, manufactured products, and construction materials used in the project are produced in the United States.”
“Project” means any activity related to the construction, alteration, maintenance, or repair of infrastructure in the U.S.
Yes. Centrisys/CNP's sourcing and manufacturing practices are continuously updated to meet the latest BABA requirements. We are prepared to fully comply with the October 1, 2025, requirement for U.S. final assembly and the October 1, 2026, requirement for 55% domestic content threshold in all applicable projects. We encourage our customers to consult with us and the latest EPA or relevant agency guidance for project-specific questions.
Yes. BABA applies to all federally funded infrastructure projects in the United States, not just those financed through the Bipartisan Infrastructure Law (BIL). This means that federal financial assistance - grants, loads, or other support whether or not originating from BIL - triggers BABA requirements if the funds are obligated on or after May 14, 2022.
Water and Wastes Digest states this means all State Revolving Funds (SRF) and Water Infrastructure Finance and Innovation Act (WIFIA) loans trigger BABA requirements, regardless of their funding being created by BIL.
The National Science Foundation (NSF) states BABA provisions apply to all new Federal-funded financial assistance awards or ongoing Federal awards that receive additional funding after May 14, 2022, involving the construction, alteration, maintenance, or repair of infrastructure in the United States.
Any funding increment, budget amendment, supplement for new or expanded scope of work, or renewal award that provides additional federal funds to an existing infrastructure award on or after May 14, 2022, will trigger revised Terms and Conditions reflecting the application of BABA provisions. This means the new or increased funding is subject to BABA's requirements for domestic sourcing of iron, steel, manufactured products, and construction materials. Recipients must review and comply with these updated requirements with each new action that increases or amends the federal funding amount.
For specific questions about your award, consult your funding agency's BABA guidance or grants officer to ensure up-to-date complance.
No, BABA only applies to infrastructure projects within the United States and its territories, not projects in other countries..
American Water Works Association (AWWA) - Understanding the Build America, Buy America Act (2025)
Wastewater Digest feature on What to Know About the Build America, Buy America Act today (2023)
Water and Wastes Digest Feature on What is Build America, Buy America (BABA)? (2022)
EPA Build America, Buy America (BABA) Website
EPA's BABA Implementation Webinar (2024)
National Science Foundation BABA (2024) FAQ
Do you have additional questions about BABA and Centrisys/CNP’s compliance with the requirements? Contact one of our decanter centrifuge and advanced biosolids treatment experts today.