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Ensuring Buy American Act Compliance for Federal Infrastructure Projects

July 05, 2022


Under the Buy American Act, federal agencies are required to use products manufactured in the United States for any contract performed within the U.S. While this law dates back to 1933, the exact requirements are continually changing, making it difficult for federal organizations and agencies to keep up.

Recently, the Biden administration revised the domestic content threshold for non-iron and steel products from 55 to 60 percent, and this number will continue to rise through 2029 when it will be required to meet a 75 percent domestic content requirement. Figuring out how to source parts and products reliably and efficiently, that meet the current percentage requirements of the law, can be a challenge.

As a 20+ year GSA contract holder with a proven track record of helping federal agencies complete large-scale infrastructure projects, Trane has a team of sourcing, supply chain, and legal experts who continually analyze government regulations to ensure products meet the highest regulation standards. With a flood of new funding about to become available through the Infrastructure Investment and Jobs Act (IIJA), now is the time to consider how you might update the indoor spaces of your buildings to improve indoor air quality and reduce greenhouse gas emissions. To do that, you need a partner well-suited for the job. 

How to Ensure Vendors are Buy American Act Compliant

Find a vendor who can help navigate complex procurement requirements
The government has many different buying options for federal contracts, each with its own set of requirements. Working with a partner who has done the legwork to become an approved GSA Schedule contract holder has many advantages. It means the vendor is pre-approved and the process for placing orders is already established. This greatly reduces timelines for getting projects started and completed and can also lead to cost savings.

Additionally, when using a GSA Schedule contract holder, certain Buy American Act requirements lessen to only needing to meet Trade Agreement Act (TAA) thresholds. Find a partner who understands these nuances and can work with you to determine the best approach for your project.

Understand the breadth of Buy American Act compliant products
You don’t want to get into a project only to learn halfway through that your vendor has limited inventory available that will meet the Buy American Act requirements. Or that they sold you a promise that, in reality, doesn’t work.  

When reviewing its product suite for federal regulation compliance, Trane took a conservative approach in what products comply with the Buy American Act. This means that products recommended for your project are well within the government regulatory requirements and commercially available off the shelf. We would rather err on the side of caution versus pushing a product that may not fully comply with the rules including compliance with 41 U.S.C. §§ 8302; FAR 52.225-2.

Protect yourself from audits
At some point, your project might be audited for compliance by the Defense Contract Audit Agency or another federal entity. In some cases, you’ll need to prove your project is Buy American Act compliant. It’s critical that your product suppliers can provide you with any required documentation needed during an audit.

Trane has supported federal agencies through the audit process before and is familiar with the level of detail that is often required. We can partner with you to ensure you have all the required documentation to seamlessly get through an audit.

The Trane Advantage
Our business is buildings. We’ve spent decades optimizing indoor spaces with the best heating and cooling systems that help buildings run more efficiently with fewer emissions. Additionally, we pride ourselves on being a strong part of America’s industrial base, with manufacturing facilities throughout the U.S.

What’s more, we have longstanding relationships with government entities and are well-versed in nuances specific to working within your parameters. Our qualifications are unmatched:

  • 20+ Year GSA Schedule Contract holder with a proven track record in helping agency partners achieve audacious goals
  • Qualified DOE ESPC contractor with expertise in scoping and executing energy-saving projects quickly and efficiently
  • 250+ North American office locations that have established relationships with local designers, suppliers, and subcontractors to deliver services
  • Registered Company – The System for Award Management ( is an official website of the U.S. Government
  • Completion of over 7,000+ task orders totaling $370M supporting Federal, State, and Local Government Agencies

Looking to scope a project that needs to be Buy American Act compliant? Get in touch today