FAR 52.225-18—Place of Manufacture.
Plain-English Summary
FAR 52.225-18, Place of Manufacture, is a solicitation provision used for statistical reporting about where offered end products are manufactured. It defines two key terms: “manufactured end product” and “place of manufacture,” including an important clarification that if a product is disassembled and reassembled, the reassembly location is not the place of manufacture. The provision then requires the offeror to indicate whether the place of manufacture of the end products it expects to provide is predominantly in the United States or outside the United States, based on which side has the greater total anticipated price of offered end products. The provision applies only for statistical purposes; it does not itself establish a domestic preference, a compliance test, or a basis for award. In practice, it helps the Government collect data on manufacturing location while requiring offerors to make a good-faith classification of the expected mix of manufactured end products in their offer. The provision is limited to manufactured end products in the specified PSC/PSG universe and excludes certain raw or agricultural categories that are not treated as manufactured end products for this purpose.
Key Rules
Statistical reporting only
This provision is used only to collect statistical information about manufacturing location. It does not create a substantive domestic source requirement, and the checkbox response is not itself a pass/fail evaluation factor unless another solicitation term makes it relevant.
Manufactured end product scope
The term covers end products in PSCs 1000-9999, but excludes the listed categories such as lumber, agricultural supplies, live animals, subsistence, crude plant and animal materials, ores, minerals, and additive metal materials. Offerors should identify only products that fall within the provision’s definition.
Place of manufacture definition
The place of manufacture is where the end product is assembled from components or otherwise made or processed from raw materials into the finished product delivered to the Government. This focuses on the location of the manufacturing transformation, not merely the location of packaging, distribution, or sale.
Reassembly is not manufacture
If a product is disassembled and later reassembled, the place where it is reassembled does not count as the place of manufacture. This prevents a mere reassembly location from being treated as the manufacturing site for reporting purposes.
Predominantly U.S. or outside U.S.
The offeror must check the box for the location that represents the greater total anticipated price of offered end products manufactured in the United States versus those manufactured outside the United States. The determination is based on anticipated price, not unit count or labor hours.
Good-faith offeror judgment
The offeror must indicate the expected manufacturing location of the end products it expects to provide in response to the solicitation. This requires a reasonable, good-faith assessment at the time of offer submission, based on the products actually being offered.
Responsibilities
Offeror
Determine which offered end products are manufactured end products under the provision’s definition, identify the place of manufacture for those products, and check either the United States or Outside the United States box based on where the total anticipated price is predominantly manufactured. The offeror must make this statement for statistical purposes in the solicitation response.
Contracting Officer
Include the provision when prescribed by FAR 25.1101(f), ensure offerors are instructed to complete the statistical reporting item, and use the information as intended for data collection rather than as a standalone eligibility test unless another solicitation clause or statute applies.
Agency
Collect and use the reported information for statistical and analytical purposes, such as tracking manufacturing location trends in procurement data. The agency should not treat the checkbox response as a substitute for any separate domestic preference, trade agreement, or Buy American evaluation requirement.
Practical Implications
Offerors should not confuse this provision with Buy American Act or trade agreement compliance; it is a reporting item, not the substantive domestic-content rule.
The key judgment is where the product is manufactured, not where the company is headquartered, where final inspection occurs, or where the item is shipped from.
Because the test is based on total anticipated price, mixed-source offers require a careful comparison of the value of U.S.-manufactured versus non-U.S.-manufactured end products.
The exclusion list matters: some commodities that may be sold in a procurement are not treated as manufactured end products for this provision, so they should not be forced into the U.S./outside-U.S. manufacturing tally.
Contracting officers should expect the provision to be completed as a statistical checkbox and should avoid overreading it as a representation of compliance with other sourcing requirements.
Official Regulatory Text
As prescribed in 25.1101 (f), insert the following provision: Place of Manufacture (Aug 2018) (a) Definitions . As used in this provision— Manufactured end product means any end product in product and service codes (PSCs) 1000-9999, except- (1) FPSC 5510, Lumber and Related Basic Wood Materials; (2) Product or Service Group (PSG) 87, Agricultural Supplies; (3) PSG 88, Live Animals; (4) PSG 89, Subsistence; (5) PSC 9410, Crude Grades of Plant Materials; (6) PSC 9430, Miscellaneous Crude Animal Products, Inedible; (7) PSC 9440, Miscellaneous Crude Agricultural and Forestry Products; (8) PSC 9610, Ores; (9) PSC 9620, Minerals, Natural and Synthetic; and (10) PSC 9630, Additive Metal Materials. Place of manufacture means the place where an end product is assembled out of components, or otherwise made or processed from raw materials into the finished product that is to be provided to the Government. If a product is disassembled and reassembled, the place of reassembly is not the place of manufacture. (b) For statistical purposes only, the offeror shall indicate whether the place of manufacture of the end products it expects to provide in response to this solicitation is predominantly- (1) □ In the United States (Check this box if the total anticipated price of offered end products manufactured in the United States exceeds the total anticipated price of offered end products manufactured outside the United States); or (2) □ Outside the United States. (End of provision)