The Build America, Buy America Act (BABA), part of the Infrastructure Investment and Jobs Act (IIJA) of 2021, requires federally funded infrastructure projects to use domestically sourced construction materials. As agencies, contractors, and suppliers adapt to these new regulations, many ask: Does hot-dip galvanized (HDG) steel meet the BABA requirements?
The answer is yes—with important considerations.
What the BABA Act Requires
BABA mandates that iron, steel, manufactured products, and construction materials used in federally funded projects be produced in the United States. Specifically for steel, this means:
- All manufacturing processes, from initial melting to finishing, must occur domestically.
- This includes coatings such as galvanizing, metallizing, or painting.
HDG Steel and Domestic Compliance
Because hot-dip galvanizing is considered part of the steel’s manufacturing process, it must be performed in the U.S. to comply with BABA.
Thus, if the steel itself is melted and manufactured in the U.S., and then galvanized domestically, the finished HDG product meets BABA’s standards.
However, steel imported into the U.S. and then galvanized here does not qualify—even if the galvanizing process occurs in an American plant. The requirement extends to the base steel itself.
Practical Implications for Contractors and Fabricators
- Verify your supply chain. Ensure both the steel mill and the galvanizing facility are U.S.-based.
- Request mill certifications. Documentation must prove the steel was melted and manufactured domestically.
- Coordinate early. Engage your galvanizer during the design phase to confirm project compliance.
- Stay updated. Federal guidance continues to evolve as BABA is implemented, so consult agencies or associations for the latest interpretations.
Why HDG Steel Is Well-Suited for BABA Projects
- Durability: HDG steel provides decades of corrosion protection, reducing maintenance costs on taxpayer-funded infrastructure.
- Domestic Availability: The U.S. has a robust network of galvanizers, ensuring supply chain capacity for BABA-compliant projects.
- Alignment with Federal Goals: Using HDG steel supports U.S. jobs, strengthens domestic manufacturing, and ensures long-lasting public works.
Hot-dip galvanized steel is fully capable of meeting the requirements of the Build America, Buy America Act—provided both the steel and the galvanizing process originate in the U.S. With proper supply chain verification and documentation, HDG steel remains a reliable, sustainable, and compliant material for federally funded infrastructure projects.
For the full technical breakdown, see the American Galvanizers Association’s article on HDG and the BABA Act.
