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 StatesAll manufacturing processes, from the initial ribboning (if applicable), through buffering, fiber stranding and jacketing, occurred in the United States.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.by identifying fiber optic cable and optical fiber as separate, singular construction materials and applying specific standards to each
How to check it without Arxo's tools
- 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). - 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). - 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). - 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
- Office of Management and Budget, Made in America Office — author of the 2 CFR 184 standards
Reported to
| Date | Institution | Channel | Reference |
|---|---|---|---|
| 2026-10-29 | Office of Management and Budget, Made in America Office — letter to the Made in America Office |
Responses
No response recorded.
Related records
- ARXO-2026-0251 — 2 CFR 184.6(a)(8): how does the engineered wood standard implement the statutory requirement for input manufacturing?
History
- 2026-10-29Confirmed by Arxo
- 2026-10-29Reported to Office of Management and Budget, Made in America Office (e-mail)
- 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.