New Specialty Metals Rules New Specialty Metals Rules for DFARS Compliancefor DFARS Compliance

• Compliance methods under FY 08 law:

• Use only US or qualifying country specialty metals

• Make/Sell COTS fasteners for COTS items

• Make commercial fasteners AND certify purchase 50% domestic metals per year

• Distributors would have to obtain self-certification from manufacturers

• See www.indfast.org for list of manufacturers and distributors utilizing 50% provision and find out how to be listed – must renew self-certification on an annual basis

• Sell fasteners under contract issued before 7/26/08 using fastener DNAD - the fastener DNAD expires for use on new contracts on 7/26/08

1

New Specialty Metals Rules New Specialty Metals Rules (cont.)(cont.)

• Utilize Prime Contractor’s one-time waivers (product made before 10/17/06; item accepted by Govt before 9/30/10)

• Any combination• www.dcma.mil/dnad - website with all current

rules (DoD Class Deviation), contract language, etc.

• Proposed Rule Public Comment Period Closed September 19, 2008

• Final rule expected with few, if any, changes in Spring 2009

2

New Specialty Metals Rules New Specialty Metals Rules (cont.) (cont.)

• Summary

• Fastener manufacturers and distributors have substantial flexibility under new law, but you must be proactive

• Understand your options

• Communicate clearly with your customers

3