Export control · US procurement law

DFARS and US procurement

DFARS, the Berry Amendment and the Buy American Act are United States procurement law. They work through contract clauses in US awards — not through export law and not through where a supplier is based.

Large white square parachute inflated on a lawn with a person next to it

What DFARS is

The Defense Federal Acquisition Regulation Supplement extends the Federal Acquisition Regulation for acquisitions by the US Department of Defense. It is not export law: it takes effect when individual clauses are written into a contract and flowed down from there to subcontractors.

Whether a requirement bites is therefore not settled by the regulation alone but by the particular contract. Two deliveries of the same product can sit under different clauses, because the contracts behind them are drawn differently.

Cybersecurity and reporting duties

The best known part is clause DFARS 252.204-7012. For certain defense contracts it requires the safeguarding of controlled unclassified information to the NIST SP 800-171 standard and the reporting of cyber incidents to the Department of Defense.

The Cybersecurity Maturity Model Certification program adds a check on the maturity of those measures in graded assessment levels. Both concern how a contractor handles information, not the technical design of a recovery system.

The Berry Amendment

The Berry Amendment is an origin rule for textiles. For certain acquisitions by the US Department of Defense it requires that fibers, yarns, fabrics and the articles made from them be grown and processed in the United States. Parachutes are named there expressly.

The rule is codified at 10 U.S.C. § 4862; before the title was reorganized it stood at § 2533a. It applies to acquisition by the Department of Defense and therefore to the supply chain of such an award — not to buyers outside that contract chain.

The Buy American Act

The Buy American Act favors domestic products in acquisitions by US federal agencies. It works with two quantities: a required share of domestic content in the product, and a price preference applied against foreign offers in the comparison. It is codified at 41 U.S.C. chapter 83.

Exceptions exist where a product is not available domestically in sufficient quantity or quality, and where trade agreements take precedence, among others. The act is an award criterion, not an export rule.

Whom these frameworks apply to

They address contractors and subcontractors in contracts of US federal agencies and of the Department of Defense. A delivery between European parties without such a contract is not reached by them.

They become relevant as soon as a project extends into a US contract chain — where a European buyer delivers as a subcontractor in a US defense award, for instance. The clauses of that particular contract then determine which evidence is required.

What this page does not say

This page explains what the named frameworks require and whom they apply to. It carries no declaration on DFARS clauses, no declaration on textile origin under the Berry Amendment and no declaration on domestic content under the Buy American Act.

Evidence of that kind is contract specific. It arises in the contract and supply chain documentation of the contractor holding the US award in question, and it is maintained there.

Source: apcodefense.com (APCO Aviation), as of 25 September 2026.

Frequently asked

Asked in technical terms.

What is the Defense Federal Acquisition Regulation Supplement?

An extension of the Federal Acquisition Regulation for acquisitions by the US Department of Defense. It is not export law but takes effect through clauses written into a contract and flowed down to subcontractors. Which requirement bites is therefore settled by the particular contract.

Does the Berry Amendment require US manufacture for parachutes?

For certain acquisitions by the US Department of Defense it requires that fibers, yarns, fabrics and the articles made from them be grown and processed in the United States, and parachutes are named expressly. The rule is codified at 10 U.S.C. § 4862, previously at § 2533a.

Do these rules apply to a supplier based in Europe?

Only where a project extends into a US contract chain, for example a delivery made as a subcontractor in a defense award. A delivery between European parties without such a contract is not reached by this procurement law, because it takes effect through contract clauses.

What does the Buy American Act require?

It favors domestic products in acquisitions by US federal agencies, through a required share of domestic content and a price preference applied against foreign offers. Exceptions exist where domestic availability is lacking or where trade agreements take precedence. It is codified at 41 U.S.C. chapter 83.

Which cybersecurity requirements does this framework carry?

Clause DFARS 252.204-7012 requires, for certain defense contracts, the safeguarding of controlled unclassified information to the NIST SP 800-171 standard and the reporting of cyber incidents. The Cybersecurity Maturity Model Certification program adds a graded check on the maturity of those measures.

Tell us what the system has to do.

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