Clauses · FAR · Supply chain and sourcing · provision
FAR 52.225-6 Trade Agreements Certificate
Does the regulation require it to flow down?
No
No regulatory flow-down mandate — 25.1101(c)(2) reaches solicitations only, and a certificate is a representation from an offeror to the Government. Primes flow it down as a supplier origin declaration for the same reason they flow 52.225-2: the prime's certificate is only as accurate as the country-of-origin data its suppliers gave it
A clause can reach your subcontract without a mandate. Once it is in your document, it is a contract term all the same. The missing mandate is a fact about the regulation. It is not a ruling on your order.
Checked against acquisition.gov on 2026-08-05 · edition Feb 2021 (no alternates; page shows FAC 2026-01, effective 2026-03-13) · base v0.9.3 Read the text ↗
What it makes you produce
2 items for your checklist, slowest first.
Something you write
Days to weeks, and nobody outside your company has to agree to it.
A record of what was actually done to the article — process routing, work content, and the change in name, character or use — because assembly on its own is not substantial transformation
FAR 52.225-6
Something you fill in and send back
Hours, once you know which one is missing.
The certification, signed, with anything that is neither US-made nor a designated country end product listed by line item and country on the schedule under it
FAR 52.225-6(a)
When it is used
Solicitation-stage provision only. FAR 25.1101(c)(2): insert 52.225-6 in solicitations that contain the clause at 52.225-5, Trade Agreements. 52.225-5 is prescribed at 25.1101(c)(1) for acquisitions valued at $174,000 or more that are covered by the WTO GPA, where the agency has determined that the Buy American restrictions do not apply to US-made end products. Above that threshold the Trade Agreements Act displaces the Buy American percentage test with a substantial transformation test. For DoD, DFARS 225.1101 directs 'Use the basic or the alternate of the provision at 252.225-7020, Trade Agreements Certificate, instead of the provision at FAR 52.225-6' — the GDMS and L3Harris templates in the corpus say precisely that ('Applies in lieu of FAR 52.225-6').
Read closely
(a) carries the certification, (b) is the list, and (c) is how the Government evaluates it; none of the three names a record. The test is not the 65 percent component test of 52.225-3: an imported component genuinely transformed can qualify above $174,000 while failing the percentage test below it, which is the most common source of confusion here. For an item bought in rather than made, the account of the transformation has to come from whoever made it. Designated countries are listed at FAR 25.003 and the list moves.
The 4 templates that name it, with the line
Source: acquisition.gov, FAR 52.225-6, FAR 25.1101(c), FAR 25.402(b), FAR 52.212-5(b)(50), and DFARS 225.1101 (verified 2026-08-05)
This is research, not legal advice. It states what the regulation says about this clause and cites the paragraph behind it. It does not rule on your order, and it does not rule on whether a prime's markings are correct.