BABA primarily applies to federally funded infrastructure projects. Gateworks’ U.S.-manufactured SBCs can contribute toward BABA domestic-content requirements when incorporated into a larger manufactured system containing items such as enclosures, radios, power supplies, and cabling.
Under the standard BABA manufactured-product rules, the finished product must be manufactured in the United States, and U.S.-mined, produced, or manufactured components must account for greater than 55% of the total cost of all components.
When a purchased Gateworks SBC is directly incorporated into the finished system, its allowable acquisition cost may count as domestic-component cost, based on its documented U.S. manufacturing and subject to the applicable funding agency’s guidance and proper documentation. Under the direct-component approach described in EPA guidance, the SBC’s internal parts are subcomponents; the SBC generally does not need to independently pass BABA’s 55% domestic-content test as a standalone finished product.
This treatment is based on the SBC’s manufacturing activities, rather than solely on its U.S. country-of-origin designation. The system manufacturer remains responsible for confirming the applicable funding agency’s requirements, documenting the component-cost calculation, satisfying the final U.S. manufacturing requirement, and certifying the finished product.