Buy America and BABA for Sign Sheeting: What Changed and When

If you bid federally funded highway work, the rules on where your sign materials were made changed in 2025, and the harder half of the requirement lands 1 October 2026. This page covers what applies, the dates, and — importantly — what we can and cannot certify for you.

The change: a 42-year-old waiver was terminated

FHWA had maintained a general waiver for manufactured products since 1983. That waiver is gone. The final rule, Buy America Requirements for Manufactured Products (RIN 2125-AG13, Docket FHWA-2023-0037), published 14 January 2025 and amended 23 CFR 635.410.

The effective date is 20 March 2025. The rule as published on 14 January carried an effective date of 17 March 2025, but FHWA then delayed it: a separate Federal Register final rule delaying the effective date (90 FR 11139, published 4 March 2025) states that “the effective date of the rule amending 23 CFR part 635 published on January 14, 2025, is delayed until March 20, 2025.” If you see 17 March quoted anywhere, including on our own pages previously, that date is superseded.

Traffic signs, sign panels and sheeting are generally manufactured products — which is precisely the category that waiver used to cover.

The two dates that matter

Both are keyed to the project obligation date, not the order date or the delivery date. Both are codified at 23 CFR 635.410(c)(1)(vii)(A) and (B).

On or after 1 October 2025 — all manufactured products permanently incorporated into the project must be manufactured in the United States. This is the final-assembly requirement.

On or after 1 October 2026 — the above, plus the cost of components mined, produced or manufactured in the United States must be greater than 55 percent of the total cost of all components.

As of late August 2026, FHWA’s Q&A documents — both updated 5 January 2026 — still print the 1 October 2026 date, and the newest item on FHWA’s Buy America page is a February 2026 proposal touching EV chargers, not signage. We found no extension, delay or new waiver. That said, our check reaches only as far as FHWA’s published material, so re-verify before you rely on it for a bid.

The trap: iron and steel reclassification

This one catches people on sign assemblies rather than sheeting.

Buy America does not apply to the non-iron/steel components of an iron or steel product. But if iron or steel cost exceeds 50 percent of a product’s total cost, the whole article is treated as an iron or steel product — that threshold is at 23 CFR 635.410(c)(1)(vi), which defines a product made “predominantly of iron or steel” as one where “the cost of the iron and steel content exceeds 50 percent of the total cost of all its components.”

Once it is in that category, it must satisfy 23 CFR 635.410(b)(1): “all manufacturing processes, including application of a coating, for these materials must occur in the United States.” Note that the coatings requirement is regulatory — it sits in 635.410(b)(1), not in the underlying Buy America statute at 23 U.S.C. 313, which carries no coatings language.

For a sign panel that is mostly aluminium and sheeting, reclassification is unlikely. For posts, breakaway bases and structural supports, it is the governing rule. The three categories — iron and steel, manufactured products, and construction materials — are mutually exclusive, so an article falls under exactly one.

De minimis: foreign steel and iron are permitted where the cost “does not exceed one-tenth of one percent (0.1 percent) of the total contract cost or $2,500, whichever is greater,” under 23 CFR 635.410(b)(4).

Waivers still in effect

The De Minimis Costs and Small Grants Waiver (88 FR, 16 August 2023) covers non-compliant products costing “no more than the lesser of $1,000,000 or 5% of total applicable costs,” or projects where total federal financial assistance is “below $500,000.” For a modest sign package on a small local project, that waiver may be the whole answer — check it before you spend effort on certification.

What we can and cannot tell you

Here is where we are going to be straight with you rather than helpful-sounding.

ORAFOL does not publish Buy America or BABA compliance documentation on its own website. We checked ORAFOL’s Americas support page, its global downloads library, its reflective solutions pages and its Engineered Matched Systems page. The compliance section carries ISO certifications, a code of conduct and a human rights statement — no BABA certificate, no domestic-content statement, no country-of-origin declarations by grade.

What does exist is third-party. Florida DOT’s PATH approved-products database lists 13 ORAFOL Americas products and marks all 13 BABA Eligible, including ORALITE 5900, 7900, AR 1000 and 5935. That is a state DOT database, not manufacturer certification, and it covers Florida’s list rather than yours.

What is confirmed is that ORAFOL Americas manufactures in Black Creek, Georgia — its stated Americas headquarters and manufacturing site for graphic solutions, reflective solutions and adhesive tapes. ORAFOL does not publish a grade-by-grade list of which SKUs are produced there versus imported from Oranienburg, Germany.

So we do not publish per-grade country-of-origin claims, and you should be wary of anyone who does. What we will do is request signed manufacturer certification from ORAFOL for the specific grades and lot sources on your project. If you have a bid with a BABA requirement, contact us early enough that the paperwork arrives before the submittal deadline, because it comes from ORAFOL, not from us.

One more caution

No FHWA Q&A document we could find names signs, sign panels, sign posts or sheeting as a worked example. Both current Q&A documents were checked. If a supplier tells you FHWA has specifically ruled on how sign sheeting is classified, ask them to cite it — we could not find that ruling, and going beyond the record on a federal compliance question is not a favour to you.

Also remember that domestic-content compliance and Type compliance are independent requirements. Satisfying BABA does not mean the material is on your state’s approved list — see which ASTM sheeting type does your state require.