Understanding DFARS Specialty Metals

Definition

DFARS, or the Defense Federal Acquisition Regulation Supplement, was created as a set of regulations to ensure the security of products procured for the Department of Defense (DoD).

Any supplier conducting work for or fulfilling contracts for the DoD is subject to DFARS compliance. DFARS itself has multiple subsections with different requirements based on what section is specified in the purchase order or customer-supplier quality agreements.

Common Clauses

'DFARS' itself is commonly used as a single qualification. However, the term 'DFARS' is really a starting point to further requirements and is not necessarily applicable on its own. To fully comply with DFARS, more specific language - such as the section/clause of DFARS - must be given to the supplier.

Some of the most common subsections of DFARS literature related to specialty metals are 252.225-7001, 252.225-7008, and 252.225-7009. These three sections are what most companies mean when saying 'DFARS.' But their content varies greatly.

DFARS 252.225-7001 – Buy American and Balance of Payments Program

Requires certain products purchased under U.S. Government contracts to be sourced from approved domestic or qualifying-country sources. This can be seen as the "master" requirement, which is refined in the other two clauses specifically about specialty metals.

DFARS 252.225-7008 – Restriction on Acquisition of Specialty Metals

Requires specialty metals delivered under the contract to be melted or produced in the United States or its outlying areas.

DFARS 252.225-7009 – Restriction on Acquisition of Certain Articles Containing Specialty Metals

Provides exceptions and flow-down requirements for specialty metals and permits material from the list of qualifying countries for most orders. (This is the most common requirement and is nearest to the removed clause DFARS 252.225-7014. This clause causes confusion because it is not as clear as 252.225-7014 was, and it is not always known to have been removed.)

Example

A supplier is sourcing product from Denmark. Denmark is a DFARS qualifying country, but it is not compliant with DFARS 252.225-7008. So, if the end user simply says DFARS but really means the product to be American made, this must be specified in the PO as a clause.

In other words, the PO simply saying "DFARS" for this situation would not fulfill end user requirements, as most DoD contracts pass through AS9100 certified companies – flow down is required through the entire supply chain.

For Purchasing Agents

Examples of customer language we commonly see:

1. "Requirement for Domestic Metal Applies per DFARS 252.225-7009" – This is an example of correct use of DFARS.
2. "Must be Domestic/DFARS" – While slightly more detailed than only saying "DFARS," "Domestic" can refer to multiple different DFARS clauses.
3. "Must be DFARS compliant", or simply "DFARS" – Widely different requirements fall under DFARS, and this can cause confusion for both supplier and customer. It leaves the supplier to assume unnecessary risk.

It is good practice for the customer to be as specific as possible regarding DFARS clauses when submitting a PO, and for a purchasing agent to work with the customer to ensure all requirements are indicated when placing an order.

When possible and if known, state a product's country of origin on all paperwork and ensure it aligns with the DFARS clause(s) required.

Furthermore, indicate if the use of the term "DFARS" is an either/or situation: meaning a country of origin on the DFARS qualifying countries list, or if the product must be domestic.

DFARS qualifying countries

Need Help Navigating DFARS?

Navigating DFARS can be challenging, and we are here to help. We acknowledge a responsibility to help inform customers regarding criteria in which we have a wealth of knowledge.

Contact M. Vincent and Associates for assistance with DFARS.

M. Vincent and Associates supplies aerospace, defense, and specialty metal products with full material traceability, DFARS sourcing support, and AS9120-certified quality management.

Influx of Demand for Aerospace Materials

On December 18, 2025, the Trump Administration published an executive order titled "Ensuring American Space Superiority." This order highlights multiple advances in aerospace and draws attention to ideas that will shape the future of the industry.

This executive order states that the United States will return to the moon by 2028, as well as establish a permanent lunar outpost by 2030. Furthermore, the United States and associating countries will deploy nuclear reactors on the moon by 2030 and in orbit. White House Executive Order. Per the executive order, $50 billion will be invested in American space markets by 2028.

Artemis Accords

The United States is part of the Artemis Accords. The Artemis Accords, created in 2020, is a group of over 60 countries and private companies that, together, create best practices and norms for space exploration and promote principles to govern the use of outer space. NASA Artemis Accords. Essentially, the Artemis Accords are the United States' and other countries' "rules" for space.

The United States and other countries in the Artemis Accords are racing to establish superiority on the moon, specifically the lunar south pole. The lunar south pole has nearly constant levels of solar illumination, meaning power, and high levels of water ice, meaning water. In addition to this, asteroid mining is gaining popularity amongst countries associated with space exploration. Countries who establish dominance on the moon will be able to create trade routes for the material. NASA and The Guardian.

The concept of asteroid mining and other cislunar development has been a hot topic over the last few years. In 2022, Johns Hopkins University published a 76-page overview of the vision of cislunar development, the need for a cislunar security strategy, establishing a cislunar economy, and some of the logistics of implementing such a vision. Artemis Accords seem to align with these values. (Johns Hopkins University)

Orion

One potential hurdle in the fight for U.S. Superiority in this sector is the logistics of the Orion Heat Shield. A heat shield is needed for spacecrafts entering the earth's atmosphere due to high velocity of entering craft, high temperature of the upper atmosphere, and friction. According to NASA, a heat shield helps to mitigate harmful solar energy and use friction to the spacecraft's advantage to slow it. Heat shields are complex to manufacture, and naturally take much time and care. Heat shield development research.

Orion spacecrafts have recently gained popular knowledge after the Artemis II crew used Orion in their historic 10-day journey to the dark side of the moon and back to earth in April 2026. The Orion heat shield performed perfectly and opened the door for further use. However, it's use for deep space exploration and long-term and use for lunar outposts requires further development.

NASA awarded Lockheed Martin a large contract in 2019 for this development of Orion Spacecrafts. The contract cites six spacecrafts to be developed throughout the contract's timeframe of 2030. According to Lockheed Martin, new and evolved knowledge of Orion is being applied to these new technologies, and there is a drive to decrease cost and manufacturing time. However, the evolution of leadership at NASA, and competing companies such as SpaceX have expanded the conversation on Orion.

In 2025, Jared Isaacman was appointed as NASA administrator. Isaacman has robust history in the private sector - a billionaire responsible for privately funding missions largely involving aerospace. As a successful entrepreneur, he came into NASA questioning long timelines and high costs associated with contracts like the one NASA gave to Lockheed Martin (SpaceNews). In a SpaceNews interview, he stresses the importance of U.S. space superiority, stating that the U.S. will "…never settle for second place." Isaacman's confirmation was met with hesitation by the senate because of his close ties and history with SpaceX.

SpaceX Influence

There is much interest in SpaceX's development with establishing a lunar outpost because of Isaacman's ties and the progress SpaceX is making in this sector. Establishing a lunar outpost is feat in amongst itself, however in-space refueling is another challenge. To have a sustainable outpost, resources are needed for it to function - with one of those resources being fuel. At this time, energy sources cannot be harvested from space (another area of interest for the Artemis Accords), so fuel must be launched from earth.

In-space refueling requires multiple in-space launches, with specific timings of these launches while in orbit. According to SpaceNews, "Starships must launch in rapid succession to transfer liquid methane and liquid oxygen to the Depot..8-16 [rockets] required to put fuel into the depot." Then, a staffed rocket retrieves the fuel, detaches from the spacecraft, then launches Orion onto the moon's surface. SpaceX appears to be rising to this challenge.

Aerospace, with SpaceX leading the charge, is big business in Texas. SpaceX is converting to a publicly traded company in 2027. At this point, the progress for in-space fuel transfer is all speculative. And although there is much support from the Texas government for SpaceX, demonstrating this transfer of fuel is crucial for public support. Countries in the Artemis accords are all essentially depending on SpaceX to reach their goal of space superiority.

New Space Race

The Artemis accords are not the only group of countries in this new space race. Countries such as China, Russia, South Africa, Egypt, and more have joined together in a program to build what they are calling the International Lunar Research Station (ILRS). Construction is expected to begin on this in 2028 and be completed around 2035. China states that they expect to work with 50 countries on the ILRS according to SpaceNews. With a similar timeframe and similar goals, such as a permanent lunar base, communications, and power, it demonstrates the urgency of global companies to source materials to reach these goals. According to McKinsey & Company, the estimated value of the space economy is expected to reach $1.8 trillion by 2035. This is almost three times the estimated value as of 2023. As companies continue to rely on technology achieved via GPS, satellites, and more, the demand for a cislunar economy is ever increasing. The Artemis accords and the countries involved in the ILRS are fighting for power in this outstanding financial outlook.

M. Vincent and Associates is pleased to offer materials for aerospace applications. As an ISO 9001 and AS9120 certified company, we can provide full traceability, DFARS compliant material, material sourcing, and a strict control policy on counterfeit parts - making us a reliable supplier for the aerospace industry. Get a quote today!

Sources

• Ensuring American Space Superiority – The White House
• NASA Artemis Accords
• NASA – Optical Mining of Asteroids, Moons and Planets
• The Guardian – Lunar Prospectors
• Johns Hopkins Applied Physics Laboratory – Cislunar Security National Technical Vision
• NASA Awards Lockheed Martin Contract for Six Orion Spacecraft
• SpaceNews – Jared Isaacman NASA Nominee
• SpaceNews – Starship In-Space Refueling Technologies
• SpaceNews – Journey to a Lunar Economy
• SpaceNews – China and the ILRS Moon Base
• McKinsey & Company – The $1.8 Trillion Space Opportunity
• Kowal, T. John. "Thermal Protection System (Heat Shield) Development – Advanced Development Project." Commercial Human Spaceflight Symposium, 2010.

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Steel and Aluminum Tariffs 2025

The current administration has issued a new executive order expanding the existing tariffs on imported steel and aluminum. As of now, these go into effect March 12, 2025.

The United States' specialty stainless steel industry has long been supplied by European mills. Our mills currently don't have the capacity or ability to produce the highly processed specialty alloys needed to supply our medical and aerospace industries. This is expected to affect costs within the medical, aerospace, and defense industries.

Key Changes That Affect Specialty Metals:

• Quotas and Exemptions to the existing tariffs are no longer an option.
• Quality, Availability and National Security concerns are no longer considered as valid reasons for exceptions (Proclamation Section 17)
• No new exclusions will be authorized for these tariffs.

How This Might Affect You

• Prices may rise: This has already been seen in the last two weeks, sometimes as much as 30% as mills look to adapt to future market conditions.
• Lead times may be unpredictable: Lead times at American mills capable of producing implant grade stainless steel are already long. They may grow.
• Quotes will be valid for short periods: The material cost you factor into your estimates may not be the cost when you're awarded the job.
• Prices on incoming mill shipments may change drastically at time of shipment.

• What You Can Do

• If you have active customer orders we strongly recommend placing orders now to lock in current prices and avoid future cost increases.
• Consider blanket orders on available stock. That pricing will not change.
• Contact your local and national representatives to push for exemptions for critical materials. Without quotas and exemptions the cost of the tariffs will no longer be spread over large quantities of product.
• Contact our account representatives directly, or through This email address is being protected from spambots. You need JavaScript enabled to view it. with any questions you may have.

Me: Can you tell me the properties and uses of 316 LVM ASTM F138 stainless steel

Chat GPT: Yes, I can tell you about the properties and uses of 316 LVM ASTM F138 stainless steel.

Properties:

1. Corrosion resistance: 316LVM ASTM F138 stainless steel has excellent resistance to corrosion, including both pitting and crevice corrosion.
2. Strength: 316LVM ASTM F138 stainless steel is a high-strength material, with a tensile strength of around 550 MPa and a yield strength of around 240 MPa.
3. Biocompatibility: This type of stainless steel is biocompatible, meaning it is safe for use in medical implants and devices.
4. Machinability: 316LVM ASTM F138 stainless steel has good machinability, which makes it easier to work with in manufacturing processes.

Uses:

1. Medical implants: The biocompatibility and corrosion resistance of 316LVM ASTM F138 stainless steel make it an ideal material for medical implants such as orthopedic implants, dental implants, and cardiovascular devices.
2. Jewelry: Due to its high strength and corrosion resistance, 316LVM ASTM F138 stainless steel is also used in the manufacturing of jewelry, particularly for body piercing jewelry.
3. Marine equipment: The corrosion resistance of this stainless steel also makes it a popular material for marine equipment, such as propeller shafts, fittings, and valves.
4. Aerospace applications: The high strength and corrosion resistance of 316LVM ASTM F138 stainless steel make it suitable for use in aerospace applications such as aircraft engine components and structural elements.

Overall, 316LVM ASTM F138 stainless steel is a versatile material with a range of applications in the medical, jewelry, marine, and aerospace industries, thanks to its excellent corrosion resistance, high strength, and biocompatibility.

Me: Can you be more specific about what types of medical implants it's used in?

Chat GPT: Sure, here are some examples of medical implants made with 316LVM ASTM F138 stainless steel:

1. Orthopedic implants: This includes hip and knee replacements, bone plates, and screws.
2. Dental implants: 316LVM ASTM F138 stainless steel is used in dental implants, abutments, and dental braces.
3. Cardiovascular devices: This includes stents, pacemaker components, and heart valve replacements.
4. Surgical instruments: Some surgical instruments, such as scalpels, forceps, and retractors, are also made from 316LVM ASTM F138 stainless steel.

In general, the excellent biocompatibility, high strength, and corrosion resistance of this type of stainless steel make it a popular choice for a wide range of medical implants and devices. It is especially useful for implants that will be in contact with bodily fluids, as it resists corrosion and maintains its integrity over time.

Here's the content of a brief conversation I had with ChatGPT about metal alloys used in the Aerospace industry. ChatGPT really put together a nice summary:

Question: What metal alloys are used in the aerospace industry?

ChatGPT: The aerospace industry uses a wide range of metal alloys for various applications due to their unique properties such as high strength, corrosion resistance, and lightweight. Here are some of the commonly used metal alloys in the aerospace industry:

1. Aluminum Alloys: Aluminum alloys are lightweight, strong, and resistant to corrosion. They are commonly used in aircraft structures, such as wings, fuselages, and engine parts.
2. Titanium Alloys: Titanium alloys are strong, lightweight, and resistant to corrosion. They are commonly used in aircraft engines, landing gears, and structural components.
3. Steel Alloys: Steel alloys are strong and durable, making them ideal for use in aircraft engines, landing gears, and other structural components.
4. Nickel Alloys: Nickel alloys are resistant to high temperatures and corrosion. They are commonly used in aircraft engines and gas turbines.
5. Magnesium Alloys: Magnesium alloys are lightweight and have high strength-to-weight ratio. They are used in aircraft components, such as helicopter gearbox housings.
6. Cobalt Alloys: Cobalt alloys are strong and resistant to high temperatures and corrosion. They are commonly used in gas turbine components and aircraft engines.

Overall, the selection of metal alloys used in the aerospace industry depends on the specific requirements of the aircraft and its components, such as strength, weight, corrosion resistance, and operating temperature range.

Question: Can you include specific alloys in your answer?

ChatGPT: Sure, here are some specific alloys used in the aerospace industry:

1. Aluminum Alloys:

• 2024-T3: Used for wing and fuselage structures.
• 7075-T6: Used for aircraft structural components that require high strength-to-weight ratio.

1. Titanium Alloys:

• Ti-6Al-4V: Used for turbine blades, compressor blades, and structural components.
• Ti-5Al-2.5Sn: Used for compressor discs and blades.

1. Steel Alloys:

• AISI 4130: Used for landing gears, engine mounts, and other structural components.
• AISI 4340: Used for aircraft engine components, such as gears and crankshafts.

1. Nickel Alloys:

• Inconel 718: Used for high-temperature applications, such as gas turbine engines.
• Inconel X-750: Used for gas turbine engine components that require high strength and resistance to high temperatures and corrosion.

1. Magnesium Alloys:

• AZ31B: Used for helicopter gearbox housings and aircraft components that require low weight.
• WE43: Used for aircraft structural components that require high strength-to-weight ratio.

1. Cobalt Alloys:

• Haynes 188: Used for gas turbine engine components, such as combustion chambers and afterburner liners.
• Stellite 6B: Used for aircraft engine valves, bearings, and pump components that require wear resistance.

There are many other alloys used in the aerospace industry, but these are some of the most common ones.

Question: What about hardenable stainless steels?

ChatGPT: Hardenable stainless steels are also used in the aerospace industry for their high strength, toughness, and corrosion resistance. These steels are capable of being hardened by heat treatment, which increases their strength and wear resistance. Some examples of hardenable stainless steels used in aerospace applications are:

1. 17-4 PH: This is a precipitation-hardening stainless steel that is used in the aerospace industry for its high strength, corrosion resistance, and fatigue resistance. It is commonly used in aircraft landing gear, structural components, and engine parts.
2. 15-5 PH: This is another precipitation-hardening stainless steel that is used in aerospace applications for its high strength and corrosion resistance. It is commonly used in aircraft engine parts, landing gear, and structural components.
3. 13-8 PH: This is a precipitation-hardening stainless steel that is used in aerospace applications for its high strength, toughness, and corrosion resistance. It is commonly used in aircraft engine parts, landing gear, and structural components.

Overall, hardenable stainless steels are used in the aerospace industry where high strength, toughness, and corrosion resistance are required, and where the weight of the component is not a critical factor. The specific choice of hardenable stainless steel alloy depends on the application and the requirements of the component.