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1. [1] DoD, Class Deviation 2026-O0015, Revision 1 (July 29, 2026): DFARS part 244 and clause 252.244-7998, Contractor Purchasing System Administration (FEB 2026)a purchasing system review when sales to the Government are expected to exceed $50 million in 12 months; 24 system criteria, including files subject to Government review; nontraditional defense contractors exempt
2. [2] DoD, Class Deviation 2026-O0050 (effective March 16, 2026): DFARS part 242 and clause 252.242-7998, Contractor Business Systems (MAR 2026)5% withheld from the final determination, 2% while an accepted corrective action plan is followed, 10% across systems, on contracts under the Cost Accounting Standards
3. [3] DoD, Class Deviation 2026-O0048, Revision 1 (July 22, 2026): DFARS part 215certified cost or pricing data above $10 million for prime contracts awarded after June 30, 2026 and above $2.5 million before; nontraditional defense contractors exempt unless waived
4. [4] Revolutionary FAR Overhaul, FAR part 15, used by DoD under Class Deviation 2026-O0048adequate price competition (15.403-2), price analysis techniques and the prior price as a valid basis for comparison (15.404-1), subcontract pricing considerations (15.404-8)
5. [5] Defense Contract Management Agency, Contractor Purchasing System Review Guidebook (September 10, 2021)the 12-month universe of transactions, the three-year cycle, the 90-day information request, bids requested, received and responsive, sole-source justification, price analysis and documentation job aids
6. [6] GAO-19-212, Contractor Business Systems (February 2019)significant deficiencies in 260 of 330 purchasing systems reviewed in fiscal years 2015 to 2017; payments withheld from 11 contractors, about $238 million, in July 2018; 15 months to 5 years or more to resolve deficiencies in six cases
7. [7] 15 CFR part 700, Defense Priorities and Allocations System (eCFR, current to October 1, 2026)DO-A1 or DX-A1 ratings for aircraft production, acceptance within 15 working days for a DO-rated order and 10 for a DX-rated order, production preference over unrated orders
8. [8] DoD, FAR overhaul class deviations for DFARS parts 209 and 225aviation critical safety items only from sources the design control activity approves (209.270-3); specialty metals, titanium included, melted or produced in the United States (225.7003-2)
9. [9] 10 U.S.C. 3014 (Legal Information Institute)definition of a nontraditional defense contractor
10. [10] US Bureau of Labor Statistics, producer price index for hot impression die, press and upset titanium and titanium alloy forgings (PCU33211233211242), not seasonally adjusted120.6 in January 2020, 131.2 in May 2021, 199.290 in August 2026 (preliminary)
11. [11] US Bureau of Labor Statistics, producer price indexes, January 2020 and August 2026 (preliminary)aerospace product and parts manufacturing (PCU3364--3364--), bolts, nuts, screws, rivets and washers (PCU332722332722), nickel alloy mill shapes (WPU10250466), steel investment castings (PCU331512331512), ball and roller bearings (PCU332991332991), iron and steel forging (PCU332111332111), titanium mill shapes (WPU10250505)
12. [12] DoD, Securing Defense-Critical Supply Chains (February 2022), Internet Archive copy of the defense.gov PDFcastings and forgings parts in 30,061 of 32,597 specialized end items identified in 2020; one US foundry able to make large titanium castings
13. [13] GAO-22-104621 (October 2021)small businesses receiving DoD contract awards fell from 42,723 in fiscal 2011 to 24,296 in fiscal 2020
14. [14] GAO-24-106649 (April 30, 2024)a missile program facing circuit card assembly lead times rising from 19 to 34 months if unmitigated; two programs with difficulty obtaining titanium and nickel in time
15. [15] GAO-25-107283 (July 24, 2025)155 mm ammunition production rising from 168,000 to 1.2 million rounds a year, with the Army qualifying suppliers for metal shells and forging
16. [16] DoD, Defense Production Act purchases, FY2025 budget justification (March 2024)precision ball bearings, solid rocket motors and forging equipment for artillery shells among munitions capacity constraints
17. [17] GE Aerospace, second-quarter 2024 earnings call (July 23, 2024)80% of material input shortages tied to 9 suppliers at 15 sites
18. [18] Boston Consulting Group, Fixing Aerospace's Supply Chain for Casting and Forging (July 17, 2024)titanium lead times about nine months; 70 to 80 weeks for a high-demand steel alloy; foundries and forges a critical choke point
19. [19] ATI, fourth-quarter 2025 earnings call (February 3, 2026)lead times for titanium and nickel alloys extending, some up to two times since the prior quarter
20. [20] US Geological Survey, Mineral Commodity Summaries 2026, Titanium (February 2026)no US titanium sponge production in 2025; net import reliance 100%
21. [21] Carpenter Technology, fourth-quarter fiscal 2026 earnings call (July 30, 2026)not taking orders two years out; engine customers more concerned with capacity than demand
22. [22] Airbus, half-year 2026 results (July 29, 2026)A320 Family rate of 70 to 75 aircraft a month expected by the end of 2027
23. [23] Boeing, second-quarter 2026 results (July 28, 2026)the 737 program began transitioning to 47 a month
24. [24] Boeing, third-quarter 2022 results (October 26, 2022)$2.8 billion of losses on fixed-price development programs, driven by higher estimated manufacturing and supply chain costs
25. [25] Northrop Grumman, fourth-quarter 2023 earnings release (January 25, 2024)$1.56 billion pre-tax charge on B-21 low-rate initial production, reflecting macroeconomic disruptions and supplier negotiations
26. [26] DFARS 252.204-7012 (May 2024)a cloud provider holding covered defense information meets security requirements equivalent to the FedRAMP Moderate baseline
27. [27] DFARS CMMC acquisition rule (Federal Register, September 10, 2025) and 252.204-7021 (November 2025)CMMC status checked before a subcontract is awarded; the prime or next higher tier sets the subcontract's level
28. [28] Northrop Grumman, supplier first article inspection requirements (revised June 3, 2024)a change in manufacturing source, process or location requires first article inspection again
29. [29] 22 CFR 122.1 (eCFR, current to October 1, 2026)manufacturers of defense articles register with the State Department's Directorate of Defense Trade Controls