DFARS Specialty Metals: What Buyers of Machined Parts Must Check

DFARS specialty metals rules restrict certain alloy steels, nickel alloys, cobalt alloys, titanium and zirconium used in items delivered to the US Department of Defense to metal melted or produced in the United States or a qualifying country. For a machined part, the question is not where the part was cut but where the bar or plate was melted. This guide explains which materials are covered, why aluminum is not, how a supplier proves compliance and why the requirement has to be in your RFQ from day one.

This article is general information, not legal advice. Confirm how the clauses apply to your contract with your contracting officer or counsel.

The legal basis: DFARS 252.225-7009 and 10 USC 4863

The restriction comes from a statute long cited as 10 USC 2533b. The FY2021 National Defense Authorization Act reorganized Title 10 and renumbered it; it now appears at 10 USC 4863 (check the current code, since older contracts and supplier paperwork still cite 2533b). The contract clause that carries it into purchase orders is DFARS 252.225-7009, “Restriction on Acquisition of Certain Articles Containing Specialty Metals”, with policy text in DFARS subpart 225.70.

The clause is a mandatory flow-down in most defense contracts for covered items (aircraft, missile and space systems, ships, tank and automotive items, weapon systems and ammunition) and for the components of those items. If the prime contract carries it, the prime flows it to you, and you flow it to the machine shop.

Which metals are specialty metals

The DFARS definition covers four groups:

1. Steel where the maximum alloy content exceeds one or more of these limits: manganese 1.65 percent, silicon 0.60 percent or copper 0.60 percent. Steel containing more than 0.25 percent of any of aluminum, chromium, cobalt, molybdenum, nickel, niobium (columbium), titanium, tungsten or vanadium is also covered.
2. Metal alloys of nickel, iron-nickel and cobalt base alloys containing a total of other alloying metals (except iron) above 10 percent.
3. Titanium and titanium alloys.
4. Zirconium and zirconium alloys.

Aluminum is not on the list. Neither are copper, brass, bronze or plastics. That makes aluminum 6061-T6 and 7075-T6 the simplest choice for housings and brackets where DFARS sourcing would otherwise add cost and lead time.

The steel limits catch more than engineers expect. Any stainless steel qualifies (chromium well above 0.25 percent). So do chromoly and tool steels. Plain carbon steels usually do not, but a heat with high residual chromium or nickel can cross 0.25 percent, which is why the actual mill chemistry matters.

Material table for common CNC alloys

Material	Specialty metal under DFARS?	Reason	What to request
Aluminum 6061-T6, 7075-T6	No	Aluminum is not in the definition	Standard mill cert; check other contract clauses
Stainless 304, 316, 316L	Yes	Chromium about 16 to 20 percent, nickel 8 to 14 percent	Mill report showing melt country, DFARS statement
Titanium Grade 2, Grade 5 (Ti-6Al-4V)	Yes	All titanium alloys are covered	Mill report showing melt country, DFARS statement
Alloy steel 4140	Yes, typically	Chromium about 0.8 to 1.1 percent, above the 0.25 percent limit	Mill report with chemistry and melt country
Tool steel D2, H13, SKD11	Yes	Chromium about 5 to 12 percent, plus molybdenum and vanadium	Mill report with melt country; hard to source compliant
Carbon steel 1018, 1045	Usually no	Manganese typically 0.60 to 0.90 percent, no significant alloying	Mill report to confirm residuals below limits
Nickel alloys (Inconel 625, 718)	Yes	Nickel base with more than 10 percent other alloying metals	Mill report with melt country
Brass C360, copper C110	No	Not steel, nickel, cobalt, titanium or zirconium	Standard mill cert
PEEK, Delrin (POM), PTFE	No	Not metals	Resin lot certificate

The 4140 case shows how to read the definition: once any one limit is exceeded, the steel is a specialty metal, so the chromium content alone puts it in scope.

Melt location versus machining location

This is the point most often misunderstood. DFARS 252.225-7009 asks where the specialty metal was melted or produced. “Melt” means reducing the metal to liquid form from ore or scrap and casting it. The clause defines “produce” narrowly, covering a small set of processes such as quenching and tempering of steel plate and certain titanium powder processes. Rolling, forging, drawing and machining in another country do not change the melt origin.

So in principle:

• Titanium melted in the US, rolled into plate, shipped to Vietnam and machined there: melt origin is US.
• Stainless bar melted in a non-qualifying country and machined in the US: not compliant, even though the part was made domestically.

Two cautions. First, the specialty metals clause is not the only sourcing clause. Buy American clauses, the Berry Amendment for certain items and program-specific terms can restrict where a component or end item is manufactured, independent of melt. Second, some primes restrict offshore manufacture as a matter of their own policy. Check the full contract flow-down, not just 7009.

For the export-control side of sending a defense-related drawing offshore, read ITAR and EAR rules for offshore CNC machining. milcnc.com does not accept ITAR-controlled technical data at all.

Qualifying countries

Specialty metal melted in a qualifying country is treated like domestic metal. Qualifying countries are those with a reciprocal defense procurement agreement with the US. The list is in the definition of “qualifying country” in DFARS 225.003, repeated in DFARS 225.872-1. It includes countries such as Australia, Canada, Germany, Japan, South Korea, the United Kingdom and most of Western Europe, but it changes over time, so check the current text before you rely on a particular mill.

Vietnam and China are not qualifying countries. In practice, specialty metal for a DFARS job machined in Vietnam has to be imported from a US or qualifying-country mill (with full paperwork), not bought from local stock of unknown origin.

Exceptions, briefly

The clause has exceptions, and they are narrow:

• Minimum content: specialty metal content not exceeding 2 percent of the total weight of specialty metals in the end item, with conditions (and limits for high performance magnets).
• Commercially available off-the-shelf (COTS) items, with some exclusions, including certain raw stock and fasteners.
• Electronic components, subject to the clause text.
• Commercial derivative military articles, under a specific procedure.
• Domestic nonavailability determinations issued by DoD for specific items.

A custom machined part to your drawing is rarely COTS. Do not assume an exception applies; get it confirmed in writing by the prime or the contracting officer.

How a supplier proves compliance

The evidence chain for a compliant part has three links:

1. Mill test report (MTR) from the producing mill, showing heat number, chemistry, mechanical properties and the country where the metal was melted. Many US mills state “melted and manufactured in USA” and “DFARS 252.225-7009 compliant” on the report.
2. Distributor certificate that carries the same heat number and states DFARS compliance. It must be backed by the mill report, not replace it.
3. Shop certificate of conformance that ties the heat number to your part number, lot and purchase order, with the MTR attached.

Red flags: a certificate that says “DFARS compliant” with no heat number, an MTR from a trading company rather than the mill, chemistry that does not match the grade or a heat number that does not appear on the material the shop received. The raw material block on Form 2 of an AS9102 first article inspection report should reference this MTR by number.

Matched suppliers through milcnc.com work with mill certificates traceable to heat number and log lot numbers per work order; see the quality page. Whether a given heat is DFARS compliant depends on the mill report, which you should review yourself.

DFARS 252.225-7052: magnets, tantalum and tungsten

A separate clause, DFARS 252.225-7052, restricts three groups of material from a covered country (North Korea, China, Russia and Iran): certain samarium-cobalt and neodymium-iron-boron magnets; tantalum metal and alloys; tungsten metal powder and tungsten heavy alloy. The core test is where the material was melted or produced. The underlying statute has also been renumbered (formerly 10 USC 2533c, now 10 USC 4872), and expanded restrictions phase in from 2027 that reach further up the magnet supply chain (mining, refining and separation), so check the current clause text.

For machined parts this matters when your assembly includes tungsten heavy alloy counterweights, tantalum components or embedded magnets. Tell the supplier up front, because compliant tungsten heavy alloy and magnet material have limited sources and longer lead times.

Why you must flag DFARS in the RFQ

Compliant material has to be purchased before the first chip is cut. If a shop quotes from local stock and learns about DFARS after award, you get one of three outcomes: a requote, a delay of several weeks while compliant bar is imported or non-compliant parts. None of them is cheap.

Hypothetical example: a batch of 200 Ti-6Al-4V brackets quoted from general stock. After award the buyer adds the DFARS requirement. The shop has to source plate from a qualifying-country mill with full certs, which can add several weeks and a material cost increase that depends on form, size and market. Stated at RFQ stage, the same requirement would have been priced and scheduled from the start.

Put this in the RFQ:

• “DFARS 252.225-7009 applies” (and 252.225-7052 if relevant)
• Required evidence: mill test report with melt country and heat number, attached to the certificate of conformance
• Whether any exception has been approved for this part, in writing

The RFQ drawing package checklist lists the other items suppliers need.

How to send this to us

Send your drawing (STEP, IGES, DWG, DXF or PDF), material callout, quantity and a clear note that DFARS specialty metals requirements apply through the RFQ form. milcnc.com screens the package under a mutual NDA, checks export sensitivity and matches it with up to 3 vetted suppliers who can source material with traceable mill certificates. Quotes include material certs, the FAI plan and lead time within 24 business hours of a complete RFQ.

Check the capabilities page for the materials routed and the export compliance page for what is out of scope. When the package is ready, submit your RFQ.