Guidance UpdateLiveGuidance Update
FHWA Updates De Minimis and Small Grants Buy America Waiver Q&As
Build America, Buy America Act (BABA)Federal Highway Administration (FHWA)US
Announced
Jan 5, 2026
Description
FHWA updated its Questions & Answers guidance for the waiver of Buy America requirements for de minimis costs and small grants applicable on or after October 1, 2025. The updated document provides clarification on implementation of the manufactured products requirements and the interplay with de minimis waiver provisions following the termination of the General Applicability Waiver for manufactured products.
Sources
Key Findings
FHWA Updates De Minimis and Small Grants Buy America Waiver Q&As
d only to provide clarity regarding existing requirements under the law or agency policies. 1. Does the USDOT De Minimis Costs and Small Grants Waiver apply to FHWA-funded projects? Yes. The USDOT De Minimis Costs Waiver applies to manufactured products and construction materials. In particular, this waiver allows use of products (manufactured products and construction materials) when the total value of such non-comp