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Many electronics and IT suppliers assume the Build America, Buy America Act (BABA) only applies to concrete, steel, or traditional construction materials. That assumption is wrong — and it’s quietly disqualifying suppliers from federally funded projects.
If your electronics or IT equipment are used in infrastructure projects supported by federal funding, BABA may apply to your products — even if you never contract directly with the federal government.
This blog explains when BABA applies to electronics and IT equipment, how these products are evaluated, and what suppliers must demonstrate to remain eligible.
When BABA Applies to Electronics and IT Equipment
BABA applies to federally assisted infrastructure projects, not to product categories.
That distinction matters.
Electronics and IT equipment fall within BABA’s scope when they are:
- Installed as part of infrastructure delivery
- Essential to the operation of infrastructure systems
- Purchased using federal financial assistance tied to infrastructure funding
Common infrastructure use cases include:
- Broadband and telecom networks
- Energy and utility systems
- Water and wastewater treatment facilities
- Transportation control and signaling systems
- Smart public buildings and municipal infrastructure
If your equipment supports infrastructure — not internal office operations — BABA applicability must be evaluated.
How Electronics and IT Equipment Are Treated Under BABA
BABA does not create a separate category for electronics. Instead, products are evaluated based on how they are manufactured and how they are used.
In most cases, electronics and IT equipment are assessed as manufactured products.
Electronics as Manufactured Products
This category commonly includes:
- Network switches, routers, and access equipment
- Control panels, PLCs, and automation systems
- Sensors, meters, and monitoring devices
- Servers and IT hardware used in infrastructure operations
- Power management and control electronics
To meet BABA requirements as a manufactured product:
- Manufacturing processes must occur in the United States
- Final assembly must occur in the United States
- Suppliers must be able to explain where and how transformation happens
Final assembly alone is not enough if core manufacturing steps occur outside the U.S.
Embedded Electronics in Infrastructure Systems
Electronics don’t avoid BABA scrutiny just because they’re part of a larger system.
Examples include:
- Smart meters embedded in utility networks
- Control electronics integrated into water treatment systems
- Traffic management and signaling electronics
- Grid monitoring and energy management devices
Even when electronics are bundled into broader systems, their origin and manufacturing process still matter.
Construction Materials: The Hidden Risk for Tech Suppliers
Some electronics and IT projects involve materials that BABA classifies separately as construction materials.
This is where many technology suppliers fail compliance reviews.
Examples include:
- Fiber-optic cable
- Glass components
- Cemented or bonded electronic housings
Construction materials must be manufactured in the United States, regardless of where electronic components are assembled.
This issue appears frequently in broadband and telecom projects.
When IT Equipment Is Usually Out of Scope
Not all IT equipment triggers BABA.
Typically out of scope:
- Office laptops and desktops
- Internal servers for administrative use
- Non-infrastructure corporate IT systems
Key distinction:
If the IT equipment supports infrastructure delivery or operation, BABA may apply. If it supports internal business operations, it usually does not.
What Electronics and IT Suppliers Must Prove
BABA compliance is evidence-based.
Electronics and IT suppliers should be prepared to provide:
- Country-of-origin declarations
- Manufacturing and assembly location details
- Description of manufacturing and transformation steps
- Material classification justification
- Sub-supplier declarations, where applicable
Generic “Made in USA” statements without supporting detail are not sufficient.
Common BABA Mistakes Made by Electronics Suppliers
These failures appear repeatedly in bid reviews and eligibility checks:
- Assuming electronics are exempt from BABA
- Treating final assembly as full compliance
- Ignoring embedded construction materials
- Reusing supplier declarations across projects
- Failing to link products to the project’s funding source
Most disqualifications occur before audits, during bid or documentation review.
How Electronics and IT Suppliers Should Prepare
Suppliers that remain eligible under BABA do the following consistently:
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Confirm BABA applicability per project Never assume — verify the funding source.
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Classify products accurately Manufactured product vs construction material matters.
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Map manufacturing steps clearly Know where transformation and assembly occur.
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Collect supplier evidence early Don’t wait until bid submission or review.
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Maintain audit-ready documentation Evidence must be traceable and retrievable on demand.
How Acquis Supports Electronics and IT Suppliers with BABA
Acquis helps electronics and IT suppliers operationalize BABA compliance by enabling:
- Product- and component-level country-of-origin tracking
- BOM validation aligned with BABA material rules
- Structured supplier declaration workflows
- Centralized, audit-ready documentation
Result: Suppliers reduce bid risk, avoid late-stage disqualification, and maintain defensible eligibility across federally funded infrastructure projects.
Final Takeaway
BABA does not exclude electronics — it evaluates them based on role, manufacturing reality, and proof.
If your electronics or IT equipment support federally funded infrastructure and you can’t clearly demonstrate:
- how the product is classified,
- where manufacturing occurs, and
- what evidence supports your claim,
…you’re exposed.
For technology suppliers, BABA compliance is no longer theoretical. It’s now part of staying eligible to sell.