What is the Buy America Act for door hardware?

There are two separate laws commonly called 'Buy America': (1) The Buy American Act (1933), which governs direct federal agency purchases and allows products from TAA-designated countries like Taiwan; and (2) the Buy America Act (transportation), which governs FHWA and FTA federally-funded projects and requires 55% domestic manufacturing cost for manufactured products like door hardware, with no TAA exception.

Does the Build America Buy America Act (BABA) apply to door hardware?

Yes. BABA, enacted November 2021 as part of the Infrastructure Investment and Jobs Act (IIJA), covers manufactured products — including door hinges, closers, and locksets — on all federally-funded infrastructure projects. At least 55% of the total cost of all components must come from US manufacturing.

Is TAA compliance the same as BABA compliance?

No. TAA (Trade Agreements Act) compliance means a product is manufactured in the US or a TAA-designated country (like Taiwan), which satisfies the Buy American Act for direct federal procurement. BABA requires that at least 55% of the cost of components be manufactured in the United States — a stricter standard that Taiwan-manufactured hardware does not automatically meet.

What door hardware manufacturers are BABA compliant?

Manufacturers with US-based production — including Hager Companies (Washington, MO), McKinney by Allegion (Scranton, PA), and LCN Closers by Allegion (Princeton, IL) — can generally claim BABA compliance for their domestically manufactured product lines. Manufacturers producing hardware overseas need to meet the 55% US component cost threshold or have the project sponsor obtain a waiver.

Who applies for a BABA waiver for door hardware?

The project sponsor (owner or prime contractor receiving the federal award) applies for the waiver, not the manufacturer or distributor. Waiver applications must be submitted to the awarding federal agency before procurement. Three grounds apply: non-availability, unreasonable cost, or public interest.

What is the 55% domestic content test for manufactured products?

The test adds up the cost of all components of the end product (for a hinge: castings, barrel, springs or hydraulic mechanism, fasteners, finish) and calculates what percentage of that total is US-manufactured. If 55% or more of component cost is domestic, the product passes. It is a cost calculation, not a final assembly location test.

Buy America Act & Door Hardware Compliance: BAA vs BABA vs TAA

Waterson Corporation • Published 2026-04-16

Direct answer: Three separate US laws govern domestic content for door hardware on government projects. The Buy American Act (1933) applies to direct federal agency purchases and allows TAA-country products (Taiwan included). The Buy America Act (transportation) and the Build America Buy America Act (BABA, 2021) apply to federally-funded infrastructure and require at least 55% US manufacturing cost — no TAA exception. Getting the wrong rule in your Division 08 71 00 section causes contract disputes at closeout.

The Four Rules at a Glance

Law	Applies to	Door Hardware Threshold	TAA-Only Hardware OK?
Buy American Act (1933)	Direct federal agency purchases (GSA, DOD)	~50–55% US content; TAA exception available	Yes
Buy America Act (transportation)	FHWA-funded highways; FTA transit projects	55% domestic manufacturing cost	No — waiver required
BABA (IIJA 2021)	All federally-funded infrastructure (FEMA, EDA, etc.)	55% domestic manufacturing cost	No — waiver required
TAA	GSA Schedule and FAR Part 25 procurement	US or designated country (Taiwan = OK)	Yes

What the 55% Threshold Means for a Door Hinge

For manufactured products under BABA and Buy America (transportation), compliance is calculated by cost. Add up all component costs — castings, barrel, springs or hydraulic mechanism, fasteners, finish plating. If 55% or more of that total represents components manufactured in the United States, the product passes.

This is a cost test, not an assembly-location test. A hinge assembled in the US from imported components can fail. A hinge assembled overseas with primarily US-sourced components might pass if the math works.

Common mistake: Specifying TAA-compliant hardware on IIJA-funded building renovations and assuming TAA = compliance. TAA satisfies the Buy American Act for direct procurement. BABA requires 55% US manufacturing cost — Taiwan-manufactured hardware does not automatically meet this.

Project Type: Which Law Governs?

Project	Governing Law	TAA-Only Hardware Eligible?
GSA Schedule purchase	Buy American Act + TAA exception	Yes
DOD direct procurement	Buy American Act	Conditional
FHWA highway project	Buy America (transportation)	No
FTA transit project	Buy America (FTA)	No
IIJA / FEMA infrastructure grant	BABA	No
State-funded (no federal dollars)	No federal requirement	Yes

Manufacturer Compliance Status

Manufacturer	Primary Production	TAA	BABA / 55% Test
Hager Companies	Washington, MO (USA)	Compliant	Compliant
McKinney (Allegion)	Scranton, PA (USA)	Compliant	Compliant
LCN Closers (Allegion)	Princeton, IL (USA)	Compliant	Compliant
Stanley / dormakaba	US operations	Compliant	Verify by product
Waterson Corporation	Taiwan	TAA Compliant (GSA listed)	Waiver required for BABA

Waiver Process: Who Applies?

The project sponsor (owner receiving the federal award) applies for waivers — not the manufacturer or distributor. Three grounds exist: non-availability, unreasonable cost, and public interest. Applications go to the awarding agency before procurement. FEMA and OMB require public comment periods before approval, so plan for the lead time.

Division 08 71 00 Specification Language (Sample)

Add a domestic preference subsection to your hardware section citing the applicable statute:

BABA / IIJA-funded: cite 41 U.S.C. § 8301 (Build America Buy America)
FHWA highway: cite 23 U.S.C. § 313
FTA transit: cite 49 U.S.C. § 5323(j)
Direct GSA procurement: cite 41 U.S.C. §§ 8301–8305 with TAA exception

Require contractors to submit a Domestic Content Certification identifying country of manufacture for each component and confirming the 55% threshold is met. Include a waiver copy if applicable.

Specifier tip: One building renovation can have multiple funding streams. Confirm the primary federal funding source and applicable statute with the owner's counsel before finalizing the hardware specification section.

Frequently Asked Questions

Q: What is the Buy America Act for door hardware?: A: There are two separate "Buy America" laws. The Buy American Act (1933) governs direct federal purchases and allows TAA-country products (Taiwan included). The Buy America Act (transportation) governs FHWA/FTA projects and requires 55% domestic manufacturing cost with no TAA exception.
Q: Does BABA apply to door hardware on IIJA-funded renovations?: A: Yes. BABA covers manufactured products including door hardware on any project receiving federal infrastructure assistance through IIJA-funded programs, including renovation work.
Q: Is TAA compliance the same as BABA compliance?: A: No. TAA satisfies the Buy American Act for direct procurement. BABA requires 55% US manufacturing cost — a stricter test that TAA-only products (like Taiwan-manufactured hardware) do not automatically satisfy.
Q: Who applies for a BABA waiver?: A: The project sponsor (owner or prime contractor), not the manufacturer. Applications go to the awarding federal agency before procurement.
Q: What documentation proves BABA compliance for door hardware?: A: A Domestic Content Certification from the manufacturer, listing country of manufacture for components and confirming 55% US content by cost. The project sponsor submits this at contract closeout.
Q: Which door hardware manufacturers are BABA compliant?: A: Manufacturers with US-based production — Hager (Missouri), McKinney and LCN by Allegion (US plants) — can generally claim BABA compliance for domestic product lines. Overseas manufacturers need to meet the 55% threshold or have the project sponsor obtain a waiver.

Source: Waterson Corporation, Door Hinge Knowledge Hub (watersonusa.ai) • Full article with Division 08 71 00 spec template →