Arxo Findings Register · Arxo Law

ARXO-2026-0250 · Reported

2 CFR 184.6(a)(4): how does the fiber optic cable standard implement the statutory requirement for input manufacturing?

Section 70915(b)(2)(A) of the Build America, Buy America Act directs OMB to ensure that its standards require that each manufacturing process required for the manufacture of the construction material and its inputs occurs in the United States. For fiber optic cable, 2 CFR 184.6(a)(4) requires ribboning (where applicable), buffering, fiber stranding and jacketing in the United States. It includes the glass and optical fiber standards and excludes the standards for non-ferrous metals, plastic and polymer-based products, and other materials. The 2023 preamble explains why OMB treated the cable as a single construction material with its own standard. One reading treats the listed processes as the definition Congress delegated to OMB. The other asks whether the manufacture of polymer and other non-fiber inputs before jacketing is also required.

Consequence

No project or product with a different result has been established. Excluding another material's standard does not by itself show that a required process was omitted.

Proposed correction

Please clarify how the starting points in 184.6(a)(4) and the treatment of non-fiber cable inputs implement section 70915(b)(2)(A).

Jurisdiction
United States — federal
Act
Uniform Guidance, 2 CFR part 184 (Buy America preferences for infrastructure projects)
Place
2 CFR 184.6(a)(4); Build America, Buy America Act, section 70915(b)(2)(A)
Record
Question of reading or data
Class
Question of reading or data
Where it arose
The text of the act
Arxo's conclusion
Confirmed
Official text
Unchanged at last check
Last checked
2026-10-29

Evidence

Pair of quotations. Quotations are verbatim from the official material; translations are ours and marked.

ensure that the standards require that each manufacturing process required for the manufacture of the construction material and the inputs of the construction material occurs in the United States
Normative text · Public Law 117-58 (Infrastructure Investment and Jobs Act), including the Build America, Buy America Act · Public Law 117-58, section 70915(b)(2)(A), 135 Stat. 1300 · retrieved 2026-10-29 · SHA-256 9f5806990c5b1a7561132fb159782891ecfb1b64bfd130b07701de7efe2aa853 · copy
All manufacturing processes, from the initial ribboning (if applicable), through buffering, fiber stranding and jacketing, occurred in the United States.
Consolidation · eCFR 2 CFR part 184 (currency through 2026-10-27) · 2 CFR 184.6(a)(4) · retrieved 2026-10-29 · SHA-256 0980f01f1f3ae8a0d4b0abe04fddb887b3f84517e5cad70e2a2c41d7591c8012 · copy
All manufacturing processes also include the standards for glass and optical fiber, but not for non-ferrous metals, plastic and polymer-based products, or any others.
Consolidation · eCFR 2 CFR part 184 (currency through 2026-10-27) · 2 CFR 184.6(a)(4), second sentence · retrieved 2026-10-29 · SHA-256 0980f01f1f3ae8a0d4b0abe04fddb887b3f84517e5cad70e2a2c41d7591c8012 · copy
by identifying fiber optic cable and optical fiber as separate, singular construction materials and applying specific standards to each
Amending act · Federal Register, 88 FR 57750 (August 23, 2023): OMB final guidance, 2 CFR parts 184 and 200, with preamble · 88 FR 57764, preamble on fiber optic cable · retrieved 2026-10-29 · SHA-256 cba9d5909881f395a5d202094e09294eeacb0c6d7210bc3e1e3119157a789539 · copy

How to check it without Arxo's tools

  1. Open Public Law 117-58 (Infrastructure Investment and Jobs Act), including the Build America, Buy America Act and find Public Law 117-58, section 70915(b)(2)(A), 135 Stat. 1300. Compare the text with the quotation above. A copy is kept in this register: 9f5806990c5b1a75-pl-117-58.pdf (SHA-256 9f5806990c5b1a7561132fb159782891ecfb1b64bfd130b07701de7efe2aa853, copy of the official file).
  2. Open eCFR 2 CFR part 184 (currency through 2026-10-27) and find 2 CFR 184.6(a)(4); 2 CFR 184.6(a)(4), second sentence. Compare the text with the quotation above. A copy is kept in this register: 0980f01f1f3ae8a0-ecfr-2-184-2026-10-27.xml (SHA-256 0980f01f1f3ae8a0d4b0abe04fddb887b3f84517e5cad70e2a2c41d7591c8012, copy of the official file).
  3. Open Federal Register, 88 FR 57750 (August 23, 2023): OMB final guidance, 2 CFR parts 184 and 200, with preamble and find 88 FR 57764, preamble on fiber optic cable. Compare the text with the quotation above. A copy is kept in this register: cba9d5909881f395-fr-2023-17724.pdf (SHA-256 cba9d5909881f395a5d202094e09294eeacb0c6d7210bc3e1e3119157a789539, copy of the official file).
  4. The finding holds if the quoted passages read as shown and the comparison gives the result stated at the top of this page. If it does not, write to us with the record ID.

How this finding was made

AI agents read the official texts and compared the provisions, clauses and preambles; they also drafted this record. A person at Arxo approved the report before it was sent.

Responsible institutions

Reported to

DateInstitutionChannelReference
2026-10-29Office of Management and Budget, Made in America Office — letter to the Made in America Officee-mail

Responses

No response recorded.

Related records

History

  1. 2026-10-29Confirmed by Arxo
  2. 2026-10-29Reported to Office of Management and Budget, Made in America Office (e-mail)
  3. 2026-10-31Entered in the register

Cite this record

Arxo Law, Arxo Findings Register, ARXO-2026-0250, https://arxo.io/findings/ARXO-2026-0250/ (status as of 2026-10-29). Data: ARXO-2026-0250.json.