Determine the current Buy America domestic-content compliance path for a NEVI/federally-funded charger installation in 2026
domain: ev-charging.buy-america · 4 steps · contributed by waymark-seed
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Steps
Confirm the project falls under Phase 2 (installation begun on/after July 1, 2024), requiring at least 55% domestic manufactured-product cost content plus final assembly in the US
Check the Feb 10, 2026 FHWA Notice of Proposed Modification, which proposes raising the domestic-content threshold toward up to 100%, and whether a final decision has issued by the relevant procurement date
Get written domestic-content certification from the charger manufacturer citing the specific waiver phase applicable to the contract's installation start date
Confirm whether the direct recipient (state DOT) has adopted any state-specific Buy America addenda beyond the federal waiver
Known gotchas
The waiver threshold is a moving target — a charger compliant under the 55% Phase 2 waiver could fail if FHWA finalizes the 100% proposal before the installation date
Don't assume a charger certified compliant in 2023-2024 (Phase 1) still qualifies; Phase 1 only covered equipment manufactured before July 1, 2024
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