Six Must-Knows about DFARS

The Defense Federal Acquisition Regulation Supplement, known as DFARS, is a foundational framework used by the U.S. Department of Defense (DoD) to govern defense contracting. Understanding DFARS is essential for any entity involved in the U.S. defense supply chain. This article provides a structured overview answering six key questions: What, Who, Which, Why, When, and How. For more non-China, domestic, and DFARS compliant materials, please check Stanford Advanced Materials.

What is DFARS?

DFARS is the supplement to the Federal Acquisition Regulation (FAR), specifically tailored for the U.S. Department of Defense. While FAR applies broadly to all federal procurement, DFARS introduces additional rules, clauses, and compliance measures focused on national defense priorities, especially concerning sensitive information, cybersecurity, and supply chain security.

DFARS adds detailed requirements that cover areas such as:

• Cybersecurity (e.g., NIST 800-171 adherence)
• Controlled unclassified information (CUI)
• Supply chain sourcing restrictions (e.g., domestic preference, non-China sourcing)
• Acquisition of specialty metals, rare earths, and electronic components

In essence, DFARS helps ensure that all goods and services procured by the DoD meet stringent national security, ethical, and sourcing standards.

Who Must Comply with DFARS?

Compliance with DFARS is mandatory for all contractors and subcontractors working with the Department of Defense. This includes:

• Prime contractors bidding on or performing defense contracts.
• Sub-tier suppliers that provide components, systems, or services used in defense products.
• Third-party service providers handling sensitive defense-related data or participating in defense-related logistics.

Even non-U.S. companies with operations or partnerships within the U.S. defense ecosystem may fall under DFARS scrutiny, especially when dealing with technical data, CUI, or cybersecurity provisions.

Which Materials and Systems Does DFARS Cover?

DFARS applies to a wide array of materials, technologies, and systems, particularly when national security or defense capabilities are involved. Some notable categories include:

• Specialty Metals: DFARS 252.225-7009 limits sourcing of titanium, steel, nickel, and other metals to domestic or allied-country sources.
• Electronic Components: Restrictions apply to sourcing semiconductors, microelectronics, and optical components from countries like China.
• IT and Cyber Systems: Contractors must secure networks according to DFARS 252.204-7012 and related cybersecurity clauses.
• Technical Data and Software: Controlled technical information must be protected in compliance with NIST standards.
• End Products: DFARS 252.225-7001 mandates that certain products must be manufactured in the U.S. or in qualifying countries (excluding adversarial nations).

Why is DFARS Important?

The importance of DFARS cannot be overstated. It serves several critical purposes:

1. National Security: By preventing adversarial access to sensitive technologies and defense information, DFARS mitigates espionage and sabotage risks.
2. Cyber Defense: DFARS cybersecurity provisions help protect DoD networks and contractor systems from increasingly sophisticated cyber threats.
3. Supply Chain Integrity: The regulation strengthens U.S. and allied manufacturing capabilities by discouraging reliance on non-trusted foreign sources (especially non-China sourcing).
4. Trade Compliance: It ensures fair competition under international agreements like USMCA while maintaining defense exceptions where needed.
5. Contractor Accountability: Through clauses and reporting mechanisms (e.g., SPRS and CMMC), DFARS ensures that contractors demonstrate real compliance, not just check-the-box claims.

When Did DFARS Emerge?

--Origins and Evolution

DFARS was first introduced in 1984 as a supplement to the Federal Acquisition Regulation (FAR). Its purpose was to address the unique procurement needs of the Department of Defense, particularly those related to national security. Since its inception, DFARS has continually evolved in response to global threats, advances in technology, and major cybersecurity incidents—such as the theft of sensitive defense data like F-35 design files.

--Comparison with FAR

The Federal Acquisition Regulation (FAR) provides procurement rules for all U.S. federal agencies, offering a general framework for acquisitions. In contrast, DFARS is specific to the Department of Defense and includes tailored clauses that address defense-related concerns such as cybersecurity, technical data protections, and sourcing restrictions.

--Comparison with USMCA

The United States–Mexico–Canada Agreement (USMCA) governs trade relations between the three countries. However, DFARS can supersede USMCA provisions when national defense is involved. For instance, while USMCA allows certain products to be sourced from Mexico or Canada, DFARS may still require those same products to be sourced exclusively from U.S. manufacturers or from approved allied nations to protect defense interests.

How to Meet DFARS Requirements?

Contractors must take proactive steps to comply with DFARS requirements. Here's how:

1. Understand the Relevant Clauses

Each defense contract will include applicable DFARS clauses. Contractors must carefully review these and understand their obligations.

2. Implement Cybersecurity Controls

For DFARS 252.204-7012 compliance:

• Perform a gap analysis against NIST SP 800-171.
• Develop a System Security Plan (SSP) and Plan of Action and Milestones (POA&M).
• Submit self-assessment scores to SPRS as per 252.204-7019.

For contracts requiring higher levels of security, companies may need to obtain CMMC certification through an accredited third party.

3. Review Supply Chains

Conduct supplier risk assessments to verify that components meet DFARS sourcing requirements (e.g., not manufactured in China if restricted). Establish documented policies to trace the origin of materials.

4. Stay Updated

DFARS clauses are periodically updated. Subscribe to DoD procurement notices or work with legal/compliance advisors to stay current.

5. Training and Audits

Train staff on DFARS compliance, especially procurement and IT teams. Be prepared for DoD audits and validations, especially under clauses like 252.204-7020.

Why Choose Stanford Advanced Materials for Your DFARS Needs?

When it comes to DFARS compliance, especially in today’s climate of rising geopolitical risks, sourcing from a trusted, domestic, and non-China-based supply chain is non-negotiable. That’s where Stanford Advanced Materials (SAM) stands out.

SAM offers a wide portfolio of DFARS-compliant materials—including specialty metals, ceramics, and rare earths—that are sourced from U.S. or allied country manufacturers, not from China or other restricted regions. The company places strict emphasis on origin traceability, ensuring all materials meet DFARS clause requirements for defense procurement.

Conclusion

DFARS is more than just a set of legal requirements—it's a national security framework that protects the U.S. defense supply chain from cyber threats, foreign adversaries, and regulatory loopholes. Knowing what DFARS is, who it affects, which materials it governs, why it matters, when it evolved, and how to comply gives companies a strong foundation for responsible, secure, and successful defense contracting.