FHWA updates BABA Q&As for Federal-aid highway projects (construction materials definitions and manufactured products phase-in dates)

FHWA published an updated Q&A document explaining how BABA/OMB guidance applies to FHWA Federal-aid highway projects. The Q&As clarify construction material coverage and definitions (including required U.S. manufacturing processes consistent with 2 CFR 184.6) and address classification issues (e.g., when combined materials become manufactured products and interactions with iron/steel content). The document reiterates the staged manufactured-products requirements tied to FHWA’s rescission of the manufactured products general waiver: for projects obligated on/after Oct 1, 2025, final assembly must occur in the U.S.; for projects obligated on/after Oct 1, 2026, final assembly plus >55% U.S. component cost applies. Compliance teams should use the updated Q&As to validate material/product classification, supplier declarations, and contract flow-downs for FHWA-funded work.