DFARS Compliance Explained: What It Is, Why It's Important, and How to Get There

cathy

For companies involved in defense contracting in the United States, DFARS familiarity and adherence are not a choice—it is a requirement. The Defense Federal Acquisition Regulation Supplement (DFARS) is a comprehensive system governing the manner in which the U.S. Department of Defense (DoD) conducts business with contractors and subcontractors. It includes regulations on everything from where to source materials and cybersecurity to quality assurance and cost accounting practices.

Let's learn about what DFARS is, why it matters, and how manufacturers and suppliers can procure and maintain compliance. Hope that you can have a better understanding of non-China, domestic, and DFARS compliant materials and their related requirements with Advanced Refractory Metals (ARM).

What Is DFARS?

DFARS stands for the Defense Federal Acquisition Regulation Supplement. It's an extension of the broader Federal Acquisition Regulation (FAR), which sets out the overall guidelines for United States government procurement. Whereas FAR applies to all federal agencies, DFARS applies to DoD contracts exclusively.

DFARS outlines concrete requirements for defense contractors, including clauses detailing how material must be procured, how data must be protected, and how contractors can ensure quality and reliability. These regulations are designed to preserve the integrity of the defense supply chain, protect national security interests, and ensure taxpayer dollars are being spent in a responsible manner.

Why Is DFARS Compliance Important?

1. Protecting National Security

DFARS defends the U.S. defense supply chain by limiting material and parts from non-allied countries, limiting foreign threats.

2. Availability of Defense Contracts

When DFARS compliance is not adhered to, companies cannot do business on most DoD projects. Even subcontractors can lose business if they don't comply.

3. Cybersecurity Controls

DFARS requires aggressive data protection practices (like those in NIST SP 800-171) to secure sensitive defense information from cyber threats.

4. Trusted Material Sourcing

Specialty metals and components must be obtained from recognized sources, traceable and of quality for critical military systems.

Substantial DFARS Clauses and Their Impact

Several clauses exist in DFARS, but some of them are very substantial to the material suppliers, manufacturers, and technology providers:

  • Degrees 252.225-7008 and 252.225-7009

These clauses restrict the acquisition of specialty metals (such as titanium, tantalum, and high-performance steel) to those which have been melted in the United States or qualifying nations. Exceptions are tight, and entities have to maintain records to determine material origin.

  • DFARS 252.204-7012

This clause addresses cybersecurity requirements, requiring contractors to take adequate security for CUI. Entities must report cyber incidents and certify that they have implemented the 110 security controls set forth in NIST SP 800-171.

  • DFARS 252.246-7007 and 7008

These clauses call for quality assurance and risk-based contractor audits. Companies must create robust quality systems to ensure that products meet stringent DoD standards.

Who is responsible for compliance?

Any company doing business under DoD contracts, directly or indirectly, must adhere to DFARS if their contracts contain applicable clauses. They include:

• Prime contractors (large suppliers to the DoD)

• Subcontractors (companies supplying components, software, or services for supply)

• Material manufacturers and distributors

• IT and cybersecurity services providers

Even small specialized businesses may fall within the scope of DFARS if their goods or services feed into a larger defense contract. Therefore, it is important to know what is required for compliance upfront.

How to become DFARS Compliant?

1. Conduct a DFARS Gap Analysis

Begin by examining your contracts and deciding which DFARS clauses apply to your business. Develop a comprehensive gap analysis to examine where your current practices are falling short.

2. Obtain DFARS-Compliant Materials

Establish relationships with competent, DFARS-approved specialty metal and component suppliers. Maintain traceability records and Certificates of Conformance (CoCs) for material used.

3. Implement Cybersecurity Controls

Follow the NIST SP 800-171 standard. This includes encrypting information, conducting regular system audits, access control, incident response planning, and staff training. Hire third-party cybersecurity advisors if needed.

4. Implement a Supplier Management System

Make sure your own suppliers are DFARS compliant as well. Put DFARS clauses in purchase orders and demand proof of compliance from your supply base partners.

5. Have Proper Records

Documentation is important. Keep audit records, material point of origin records, cybersecurity training records, and system settings. You need to be able to demonstrate compliance at a moment's notice.

6. Register with SPRS

Complete and submit your NIST 800-171 self-assessment score to the Supplier Performance Risk System (SPRS). This is mandatory in a demonstration of cybersecurity readiness.

Your Trusted DFARS-Compliant Supplier: Advanced Refractory Metals (ARM)

Advanced Refractory Metals (ARM) specializes in supplying DFARS-compliant specialty metals, including titanium, stainless steel, nickel alloys, and cobalt alloys. In line with DFARS 252.225-7009, all materials are sourced from the U.S. or qualifying allied countries. We provide full traceability and certification to support your defense and aerospace projects with confidence and compliance.

Conclusion

DFARS compliance is more than a regulatory check-box. DFARS compliance represents a commitment to national security, operational integrity, and adherence to ethical business practices. Whether you are a prime contractor or a third-tier supplier, compliance with the requirements of DFARS means your company has the credibility and qualifications to be part of U.S. defense initiatives. For more domestic, non-China, DFARS-compliant materials, please check our homepage.

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