Why Federal Award Origin Fields Cannot Map the Defense Supply Chain

A Buy American classification can be useful for domestic-sourcing compliance. It is not a supply-chain map.

That distinction sits at the center of a July 2025 Government Accountability Office review. The Federal Procurement Data System showed the United States as the place of manufacture for about 95 percent of the obligations for goods the Department of Defense procured from FY 2020 through FY 2024. It showed the United States as the country of origin for about 96 percent of those obligations by dollar value. The first field classifies the manufactured end product. For a non-domestic product, the second records one country representing the preponderance of foreign content. Neither field identifies the origin of every component or material.

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The apparent contradiction disappears once the unit of analysis is clear. Award data describe the government’s direct contract action. Supplier risk can sit several commercial transactions deeper.

Why the end-item record stops too soon

GAO analyzed two sourcing fields in the Federal Procurement Data System. GSA moved the system’s public-facing contract-award search to SAM.gov and retired FPDS ezSearch on February 24, 2026, but the underlying contract-award records remain available through SAM.gov. [6]

The current DOD reporting instruction tells contracting officers to select Manufactured in the U.S. when supplies are considered domestic end products. Other selections cover foreign manufacture under trade agreements, qualifying-country treatment, or a named Buy American exception. Country of Product or Service Origin is a separate, single-country field. Neither is a component-by-component bill of origin. [7]

The legal classification is narrower than an all-American supply chain. Under the current basic DFARS clause, an end product that is neither wholly nor predominantly iron or steel and is manufactured in the United States generally meets the content test when the cost of U.S. and qualifying-country components exceeds 65 percent for items delivered in calendar years 2024 through 2028. The stated percentage rises to 75 percent beginning in 2029, subject to the alternate percentages and exceptions described in the clause. For that category of end product, a commercially available off-the-shelf item is exempt from the component test. Products made wholly or predominantly of iron or steel use a separate test under which non-U.S. and non-qualifying-country iron and steel must account for less than 5 percent of total component cost.

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GAO used the F-35 record to illustrate the gap. Of 115 active related contracts in its fiscal 2020–2024 review, the United States was listed as the country of origin for 114. The government nevertheless knew, through information outside that top-level contract dataset, that magnets on some aircraft had originated in China. [5]

This does not make the award fields inaccurate for their intended purpose. It makes them insufficient for a different purpose. Domestic-source compliance answers whether an end product meets an applicable rule. Supply-chain illumination asks which business entities, facilities, processes, parts, and raw materials make that product possible and how those relationships change.

The visibility ladder

The public record describes layers of supplier information that become harder to collect as the map moves farther from the prime contractor.

Layer	What the record can show	What remains uncertain
Award record	Prime contractor, purchased item or service, action value, and obligations	Component, equipment, and raw-material origins
DIBMAP	Primes and generally the next two supplier tiers across hundreds of systems	Much of the lower-tier network where material dependencies can sit
SCREEn	Part- and supplier-level information for selected weapon systems	Comprehensive coverage and proactive identification across all tiers
Program and prime disclosures	Program-specific supplier records and risks disclosed by prime contractors	Consistent enterprise coverage; some disclosures occur only after a problem is found
Contract deliverables	Supplier information required as part of contract performance	Cost, scope, data rights, proprietary protections, and feasibility remain to be tested

This ladder is an editorial synthesis of the GAO record, not a score of operational effectiveness. GAO also noted that other government supplier systems exist but were not designed to provide this kind of supply-chain visibility. [5]

Two mapping efforts show the same lower-tier boundary

The department pursued two prominent visibility efforts during the five years GAO reviewed.

The Supply Chain Risk Evaluation Environment, or SCREEn, began with selected F-35 supply chains. As of April 2025, officials said it held country-of-origin information for first- and second-tier suppliers associated with 30,000 of roughly 40,000 targeted F-35 parts. But they estimated that it had origin information for less than 10 percent of all suppliers providing components and raw materials for those parts. [5]

The Defense Industrial Base Modeling and Analysis Project, or DIBMAP, began as a collection effort for 110 weapon-system programs. It later contained information on 732 systems and programs. Officials said it generally captured primes and the next two supplier tiers, and sometimes more. They also said it still did not provide enough lower-tier visibility to identify and proactively address foreign dependencies. Development was on pause as of March 2025 while next steps were considered. [5]

The government does have substantial information about selected systems, priority sectors, known risks, and top-tier suppliers. Coverage is uneven. GAO found that visibility weakened in the lower tiers where raw-material, parts, and equipment dependencies can remain. [5]

Voluntary data reaches an economic limit

Lower-tier mapping is not only a technical problem. It is a contracting and incentive problem.

GAO reported that the Defense Logistics Agency tried to gather data from 63 suppliers across three classes of goods. Thirty-seven agreed to provide information, 22 declined or did not respond, and four were still evaluating the request. Only five complete responses had arrived. Officials said the limited participation removed the value from the planned analysis. [5]

Suppliers cited the absence of a contractual duty, additional work, limited resources, and concern about proprietary information. DOD officials and industry representatives disagreed about how much contractual collection would cost, particularly when reconstructing lower-tier origin after award. GAO did not quantify the burden by company size. [5]

A workable requirement therefore has to define which data support a decision, which supply chains justify the burden, who may access the information, how commercially sensitive records are protected, and how accuracy will be tested.

Buying a commercial map does not eliminate verification

Government organizations also use commercial supply-chain tools. These products combine corporate records, shipping information, public disclosures, and other datasets to infer relationships and flag risks. They can find ownership changes and connections that a contract database cannot.

They are still inference systems. GAO cited a 2024 Air Force assessment of three commercial tools that rated the supply-chain illuminations 60 to 70 percent accurate. The assessment found false positives and missed suppliers. [5] The public GAO report does not provide the assessment’s denominator or a tool-by-tool result, so the range should not be treated as a universal accuracy rate. Any operational map needs visible confidence, provenance, and verification status.

The right question is not whether commercial data or contractor-provided data is universally better. It is which claim each source can support:

• An award system records the government’s direct contract action.
• A contractor’s enterprise system may contain approved-supplier and inventory records that are not in the award system.
• Shipping and corporate datasets can identify candidate relationships.
• Program officials can test whether a flagged dependency applies to a specific system.

Those records must be reconciled rather than collapsed into one unqualified network graphic.

Policy recognized the gap before implementation caught up

Executive Order 14017, signed on February 24, 2021, directed DOD to submit a defense-industrial-base supply-chain assessment within one year. [1] The January 2024 National Defense Industrial Strategy made resilient supply chains one of four priorities. Its proposed actions included expanding the supplier base and using data analytics to improve sub-tier visibility. [2]

The July 2024 interim implementation release said many initiatives had received funding through Defense Production Act and Industrial Base Analysis and Sustainment programs. [3] GAO later counted about $6.5 billion obligated across 828 industrial-base investment projects from FY 2020 through FY 2024.

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Those investments may mitigate known gaps. The total does not show that the department can see all dependencies, that every project added qualified output, or that a funded capacity will receive sustained demand. Investment activity and risk reduction are different measures.

The operating model remained unfinished

The Defense Business Board’s January 2025 study defined illumination as a continuing process rather than a one-time picture. It recommended clearer leadership, priority setting, data standards, enterprise sharing, and contractual data requirements informed by private-sector practice. [4]

In its July 2025 report, GAO found that the department had established a Supply Chain Risk Management Integration Center but had not identified resources, priorities, and time frames for the relevant integration work. It also found that responsibility for implementing the business board’s leading practices had not been assigned and that the department had not tested contract deliverables for country-of-origin information. The department agreed with GAO’s three recommendations. [5]

GAO’s live recommendation tracker still listed all three recommendations as open on August 28, 2026. The tracker records a January 2026 DOD plan to use a Supply Chain Risk Management Integration Cell for governance, leading-practice implementation, and work related to country-of-origin collection. DOD expected to complete the actions by June 2026. The open status means GAO had not closed the recommendations; it does not establish that no work occurred after DOD’s January update.

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The contract question therefore remained unresolved in GAO’s public status record. Some officials believed supplier information could be extracted from systems companies already use. Other officials and industry representatives warned that reconstructing lower-tier origin after award could be expensive. GAO recommended testing additional contract deliverables to identify the benefits and challenges rather than assuming either position was correct.

A 2026 directive broadened the prospective requirement

Executive Order 14415, signed July 20, 2026, directs the Secretary of War to develop policy and implementation guidance within 180 days for mapping designated critical supply chains. The order calls for prime contractors and subcontractors at any tier to provide an indentured bill of materials tracing covered components, parts, equipment, software, and materials to raw-material origin. It also calls for supplier vetting, mitigation, notification, and implementing regulations within 90 days after the policy and guidance are completed. [10]

The order requires the implementing regulations to account for the compliance burden on small businesses, nontraditional defense companies, and new entrants. It is a direction to develop policy and regulations, not evidence that those regulations were final or that the covered supply chains had been mapped by August 28, 2026. The policy question is now how the department will define the covered acquisitions, protect proprietary information, test submitted data, and administer the requirement across tiers.

What a credible visibility metric would measure

Counting mapped entities is tempting but insufficient. A credible operating dashboard would need to distinguish at least five dimensions:

1. Coverage: What share of the relevant parts, suppliers, and material spend is represented?
2. Depth: How many tiers are mapped, and where does the map stop?
3. Verification: Which relationships come from a contractual record, a supplier attestation, a commercial inference, or a program-office review?
4. Freshness: When was each relationship last checked, and what event triggers an update?
5. Decision value: Did the information identify a risk, qualify an alternative, change inventory, or support an investment decision?

A sixth measure, supplier burden, belongs beside them. GAO documented limited resources as one reason for nonparticipation, while Executive Order 14415 directs the eventual regulations to avoid unduly burdening small businesses, nontraditional defense companies, and new entrants. [10]

What manufacturers and investors should take from the gap

For a manufacturer, the record suggests that verified traceability is becoming a business capability. The useful product is not a decorative network diagram. It is the ability to connect an end item to controlled supplier, part, process, and origin records without exposing information beyond the people authorized to use it.

For an investor, an apparently domestic prime contract does not settle exposure to foreign processing, single-source materials, or an unqualified alternative. Diligence should ask where management’s map ends, when the underlying records were checked, and which relationships were verified.

GAO and the Defense Business Board favored testing and prioritizing collection. Executive Order 14415 sets a broader direction but leaves the Secretary of War to designate critical supply chains and requires the regulations to address burden on smaller and newer suppliers. Implementation will have to reconcile those two demands: broad enough coverage to find lower-tier dependencies and narrow enough data requirements to support verification and continued participation.

The useful distinction is this: origin fields classify the purchase; visibility describes the production system. A high domestic percentage in award data cannot establish that the supply chain beneath the end product is visible, diversified, or ready to scale.