Made-in-America Won't Secure the Pentagon's Supply Chain

A defense contractor can know where a component was assembled and still have no visibility into the companies behind it. A domestic supplier may depend on an overseas manufacturer owned through entities spanning several jurisdictions. A country-of-origin designation alone can’t reveal those relationships.

Knowing where a part was made is only part of that work. Contractors must also establish who owns and controls the companies involved in producing it.

A prime contractor may have thoroughly vetted its direct supplier without knowing that several upstream companies share a foreign parent or depend on the same manufacturer. Supplier certifications and questionnaires provide useful information, but they may leave significant gaps below Tier 1.

EO 14415 directs prime contractors and subcontractors at any tier to map critical supply chains from raw materials through finished products. It also calls for vetting suppliers for foreign ownership, control or influence. The order’s January 2027 restrictions on certain sourcing waivers add urgency. Contractors seeking a waiver for covered materials after that date need to provide the non-compliant source, evidence of exhaustive sourcing efforts, removal steps, and a remediation plan. Failing to qualify a domestic source of covered materials does not count as non-availability, meaning “we couldn’t clear anyone else” will not work unless you can show active, funded, ongoing qualification efforts. 

Much of the information needed to do this is scattered across corporate registries, trade records and procurement databases. Companies may appear under different names across jurisdictions, while ownership records and shipment data often provide only a partial view.

Connecting those records can reveal risks that conventional screening misses. Several  independent suppliers may rely on the same upstream manufacturer, creating a single point of failure across multiple defense programs. A change in ownership may introduce new exposure after a supplier has passed its initial review. A supply-chain map developed when a contract was awarded may no longer reflect the companies supplying the program a year later.

Contractors need continuous monitoring to account for these changes. 

Contractors should begin with the components, materials and programs where an upstream disruption or undisclosed relationship would have the greatest consequences. They must establish how far below Tier 1 their existing supply chain visibility extends.

That work requires connecting supplier, trade and corporate records, investigating gaps and retaining audit trails behind each finding. Commercial intelligence capabilities can help identify sub-tier entities, uncover ownership relationships and flag changes that warrant further investigation.

The objective is to establish a reliable, current picture of the companies and materials supporting critical defense programs, with records that can substantiate the contractor’s conclusions.

A Made-in-America label can tell the Pentagon where a component was made. It can’t establish who controls production or where the source materials originated. As defense supply-chain regulations evolve, contractors will need to demonstrate both.

Owen Denby is General Counsel of Sayari, where he oversees the company’s legal and regulatory affairs globally. The US Intelligence Community, Federal Law Enforcement, and Fortune 500 enterprises across more than 35 countries rely on Sayari for supply-chain visibility.