The signing of Executive Order 13920 on January 25, 2020, represented a clear policy shift toward tighter domestic sourcing requirements in the name of national security and economic resilience. Intended to fortify critical infrastructure sectors, the order reinforces and expands the Buy America framework by placing greater emphasis on local content requirements for materials such as steel, aluminum, and semiconductors. For federal contractors, the implications are significant—and immediate. Meeting the order’s expectations demands not only operational adjustments but also a more rigorous understanding of the composition and geography of supply chains that feed into government projects.
At a glance, it might seem straightforward enough: source more components and materials from within U.S. borders. Yet the real challenge lies in verifying and documenting that supply chains comply with the localization mandates in both letter and spirit. The complexity deepens when one considers the extent of globalization embedded within Tier 1 and Tier 2 supplier networks. Many contractors have discovered that while final assembly may occur domestically, key inputs or subcomponents are imported, sometimes indirectly, through upstream suppliers. This is precisely where the order’s requirements place contractors under new pressure to trace supply origins with greater accuracy.
One practical strategy is to begin mapping supply chains using publicly available data resources, such as the National Institute of Standards and Technology’s Manufacturing Extension Partnership (NIST MEP) database. The MEP network, with its regional centers and partnerships across the country, offers valuable insights into domestic manufacturing capabilities and supplier directories. Federal contractors can use this data to identify potential U.S.-based suppliers that could replace foreign sources, or at least bolster their domestic sourcing ratios in sensitive sectors. By aligning procurement databases with MEP records, companies can start to visualize the proportion of materials sourced locally versus internationally—and crucially, identify gaps where reshoring efforts might focus.
A related task involves engaging with existing suppliers to verify the origins of critical inputs. Contractors might find it useful to introduce supplier questionnaires or attestation forms focused specifically on Buy America compliance. Such documents would seek confirmation of where steel, aluminum, and semiconductor components are produced and processed, with supporting documentation where feasible. Inevitably, some suppliers will struggle to provide clear answers, or may themselves be reliant on imported inputs. This, in turn, could guide strategic decisions about supplier retention, substitution, or collaboration on reshoring initiatives.
Transparency is becoming as important as compliance itself. The federal procurement guidelines linked to Executive Order 13920 increasingly expect contractors to demonstrate their supply chain localization efforts proactively. This means publishing accessible, well-structured Buy America supply chain summaries. Such summaries typically outline key sourcing statistics—for example, the percentage of steel or aluminum sourced from domestic mills—while highlighting partnerships with U.S.-based manufacturers. Contractors might also choose to include a narrative element, describing how their sourcing strategies have evolved in response to the executive order, and what further steps are planned to enhance compliance over time.
Crafting these summaries is not purely a box-ticking exercise. There is value in treating them as a communications tool for engaging stakeholders, from government contracting officers to the broader public. Some firms have already begun to post their Buy America supply chain summaries on corporate websites or include them as appendices to annual reports, framing their efforts as part of a broader commitment to supporting U.S. manufacturing and infrastructure. This not only reinforces regulatory alignment but helps build goodwill in an environment where domestic sourcing is increasingly viewed as a marker of corporate citizenship.
What complicates matters, of course, is the inevitable friction between economic efficiency and policy compliance. The reshoring of certain components—semiconductors being a prime example—presents substantial cost and capacity challenges that no amount of database mapping can fully resolve in the short term. Contractors are left balancing the desire to meet Buy America requirements against the practical realities of global supply constraints and price competitiveness. Some have responded by initiating joint ventures or long-term supply agreements with domestic producers, seeking to secure future capacity even as they navigate present limitations.
It remains to be seen how strictly enforcement mechanisms tied to Executive Order 13920 will be applied in practice, but the policy trajectory is unmistakable. Federal contractors that take early, visible steps to map, document, and communicate their domestic sourcing strategies will likely be better positioned—not only for compliance but also for competitive advantage in bidding for government contracts. The path forward may not be simple, and no single framework offers a perfect solution. Yet the combination of NIST MEP data, supplier engagement, and transparent reporting provides a foundation for contractors determined to meet both the spirit and the technical requirements of this evolving Buy America landscape.