PRODUCTS
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U.S. Government Sourcing Programs
Stimulate Domestic Manufacturing Strengthen Supply Chains
The U.S. government offers programs promoting and prioritizing domestically sourced and produced goods. Each program has its own requirements and reporting methods. Several have similar names and cause confusion.
Simplifying compliance considerations, you can confidently specify Tubelite brand products made with our EcoLuminum – aluminum with a high recycled material content composition. We always rely on secondary (recycled) billet that is sourced from the United States for our production. This means EcoLuminum can be used in manufacturing products for projects requiring Build American, Buy America (BABA) threshold compliance.
Buy American Act of 1933 (BAA - 41 U.S.C. §§ 8301-8305)
The BABA Act was signed into law as part of the 2021 Infrastructure Investment and Jobs Act, strengthening the earlier requirements for federally financed infrastructure projects. BABA:
- Establishes a domestic content procurement preference,
- Affects all iron, steel, manufactured products, and construction materials used in covered infrastructure projects, and
- Requires that these products and materials are produced in the United States, currently at a minimum of 55% of the overall products by cost.
Buy America
- Was enacted in 1982 as part of The Surface Transportation Assistance Act.
- It extended preference requirements to purchases made by third parties (private contractors) for projects that are at least funded in part by federal grants for infrastructure, such as highways, railways and airports.
- With this act the definition of “American-Made” was expanded to include all steel and iron components of end products must be mined, melted, and manufactured in the U.S. However, there is one important exception: foreign-sourced materials may be allowed if they are valued at $2,500 or 0.1% (whichever is greater) of the contract value, this is known as the “minimal use amount.”
- Essentially, goods must be 100% manufactured in the U.S. and all steel and iron components MUST be mined, melted and manufactured in the U.S.
Build America Buy America (BABA)
This was enacted as part of the Infrastructure Investment and Jobs Act on November 15th, 2021.
- Establishes a domestic content procurement preference
- Affects all iron, steel, manufactured products, and construction materials
- Materials/products affected are used in covered infrastructure projects
- Requires that these materials/products are produced in the United States currently at a minimum of 55% of the overall products by cost.
Apogee Architectural Metals can work with you to help comply with these various programs in one or both of two ways:
- Secondary Billet (always domestically sourced in the United States for our production) can be used for manufacturing of the projects requiring Buy American, Buy America, and BABA threshold compliance.
- Evaluate each project individually, analyzing compliance eligibility based on the selected products.
Project Letter of Compliance
Based on your product selection, each project can be reviewed and analyzed individually for compliance eligibility. A letter of compliance also can be provided to describe the project and its products’ specific material composition.
Talk to Our Sustainability Experts
Have questions about meeting LEED v4/v5 requirements, securing government project approvals, or selecting the best system for energy performance? Contact our Architectural Services team for personalized support.


David Heckert
240.425.8791
dheckert@apog.com
- Northeast Region
- Southeast Region

Tyler Lemke
715.846.3840
tlemke@apog.com
- Midwest Region
- South Region







