2 CFR 184.6(a)(8): how does the engineered wood 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 engineered wood, 2 CFR 184.6(a)(8) covers all manufacturing processes from the initial combination of constituent materials until the wood product is in its final form. The 2023 preamble says that only the engineered wood standard applies, even though the lumber and polymer standards could otherwise apply, and explains the standard by the manufacturing processes used in the industry. One reading treats the combination of constituents as the starting point OMB chose under its delegated authority. The other asks whether the manufacture of previously manufactured lumber inputs is also required.

Consequence

No project or product with a different result has been established.

Proposed correction

Please clarify how the starting point in 184.6(a)(8) and the treatment of previously manufactured lumber 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)(8) and (b); 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

All manufacturing processes from the initial combination of constituent materials until the wood product is in its final form, occurred in the United States.

Paragraph (b) clarifies that only the single standard for engineered wood applies to a product falling in that category.

OMB believes that this revised standard accurately reflects the discrete manufacturing processes used in the production of engineered wood.

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)(8). 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 57783, preamble on paragraph (b) of the standards; 88 FR 57783, preamble on the engineered wood standard. 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

• Office of Management and Budget, Made in America Office — author of the 2 CFR 184 standards

Reported to

Responses

No response recorded.

Related records

• ARXO-2026-0250 — 2 CFR 184.6(a)(4): how does the fiber optic cable standard implement the statutory requirement for input manufacturing?

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-2026-0251, https://arxo.io/findings/ARXO-2026-0251/ (status as of 2026-10-29). Data: ARXO-2026-0251.json.