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There is no official list of “DFARS compliant countries.” The phrase usually points to the DFARS definition of a qualifying country, a country with a reciprocal defense procurement agreement with the United States. That definition is in DFARS 225.003, and it is the one the specialty-metals clause (DFARS 252.225-7009) relies on. This page lists the 28 countries named in the definition as of 2026-10-29, and explains what the label does and does not mean.
What “qualifying country” means and who maintains it
The Defense Federal Acquisition Regulation Supplement (DFARS) is the Department of Defense supplement to the Federal Acquisition Regulation. Part 225 covers foreign acquisition, and its definitions section, 225.003, defines the term. As of 2026-10-29 on acquisition.gov, a “qualifying country” is a country with a reciprocal defense procurement memorandum of understanding or international agreement with the United States, in which both countries agree to remove barriers to purchases of supplies produced in the other country or services performed by sources of the other country. The memorandum or agreement must also comply, where applicable, with section 36 of the Arms Export Control Act (22 U.S.C. 2776) and with 10 U.S.C. 2457.
The point that most searches miss: this is a procurement-reciprocity status attached to a country, not a certification that a company, product or information system has met a security or quality standard. No contractor, university or laboratory is “DFARS compliant” by virtue of where it sits.
The list of qualifying countries (DFARS 225.003)
As of 2026-10-29, on the official DFARS Part 225 page, the definition ends with the words “Accordingly, the following are qualifying countries,” followed by these 28 entries. This is also the answer to the variant search “dfars countries.”
- Australia
- Austria
- Belgium
- Canada
- Czech Republic
- Denmark
- Egypt
- Estonia
- Finland
- France
- Germany
- Greece
- Israel
- Italy
- Japan
- Latvia
- Lithuania
- Luxembourg
- Netherlands
- Norway
- Poland
- Portugal
- Slovenia
- Spain
- Sweden
- Switzerland
- Turkey
- United Kingdom of Great Britain and Northern Ireland
The regulation changes through DFARS rulemaking, so read the current text before relying on a list copied from any secondary source, including this page. The official source is DFARS Part 225, Foreign Acquisition, on acquisition.gov.
Where the term does its work: DFARS 252.225-7009
The clearest place the definition has legal effect is the clause 252.225-7009, Restriction on Acquisition of Certain Articles Containing Specialty Metals (clause date JAN 2023; the acquisition.gov page header shows DFARS Change 5/7/2026). The clause does not keep its own list. It defines “qualifying country” as any country listed in the definition at 225.003, so an update to the list in 225.003 flows into the clause automatically.
As of 2026-10-29, the official clause page provides:
- The restriction, paragraph (b). Except as provided in paragraph (c), any specialty metals incorporated in items delivered under the contract must be melted or produced in the United States, its outlying areas, or a qualifying country.
- Exception (c)(4). The restriction does not apply to “items manufactured in a qualifying country.”
- Exception (c)(5). The restriction does not apply to specialty metals for which the Government has determined, in accordance with DFARS 225.7003-3, that metal melted or produced in the United States, its outlying areas, or a qualifying country cannot be acquired as and when needed in satisfactory quality, sufficient quantity, and the required form.
The clause has other exceptions as well, among them electronic components in (c)(1), certain commercially available off-the-shelf items in (c)(2) and certain fasteners in (c)(3). Those do not depend on the country list and are outside this page. Read the full clause for the contract in front of you.
Eligibility: what the list does and does not decide
| Question | What the sources say |
|---|---|
| Is a country on the list a “DFARS compliant” country? | The definition makes it a “qualifying country” because of a reciprocal defense procurement agreement. It is a country status, not a compliance certification. |
| Where must specialty metals be melted or produced under 252.225-7009(b)? | The United States, its outlying areas, or a qualifying country, unless a paragraph (c) exception applies. |
| Does manufacturing in a qualifying country matter separately? | Yes. Paragraph (c)(4) excepts items manufactured in a qualifying country. |
| Who maintains the list? | It is part of DFARS 225.003 itself, so it changes only through changes to that regulation. |
Not the same as CMMC or DFARS cybersecurity compliance
Searchers often arrive here wanting to know which countries can host systems or staff that handle defense data. That is a different regime. Cybersecurity obligations in defense contracts run through other DFARS clauses and the Cybersecurity Maturity Model Certification program, and they attach to the contractor and its information systems, not to a country list. CASRAI covers them separately: see DFARS 252.204-7021 and the CMMC clause, CMMC for universities and research institutions and the dictionary entries for NIST SP 800-171 and controlled unclassified information. Export-control questions about which foreign persons may access a technology are likewise separate; see the four pillars of export control compliance.
Compliance steps for a research office
The following steps follow directly from how the clause is written. They are a reading order, not legal advice.
- Find out whether 252.225-7009 is in the contract at all. The restriction applies to items delivered under a contract that includes the clause. Whether your award is a contract or a grant is a threshold question; see federal contracts vs. grants for university research.
- Identify what is delivered. Paragraph (b) reaches specialty metals incorporated in items delivered under the contract, so the question is about deliverables, not lab consumables.
- Trace where the metal was melted or produced. Compare that place with the United States, its outlying areas, and the 28 countries in 225.003.
- Check the exceptions in paragraph (c). A foreign melt location may still be acceptable if, for example, the item was manufactured in a qualifying country under (c)(4).
- Re-read the list on the date you decide. The list is regulation text and can be amended.
Obligations that apply to every federal contractor are summarised in federal contract compliance: the FAR obligations that apply to contractors.
Common mistakes
- Treating the list as a cybersecurity or data-hosting approval. The definition concerns reciprocal defense procurement agreements, as the 225.003 definition states.
- Confusing “melted or produced in” with “manufactured in.” Paragraph (b) speaks of where specialty metals are melted or produced; paragraph (c)(4) speaks of where items are manufactured. They are separate tests.
- Copying an old list. Secondary pages go stale; the definition in 225.003 is the authority.
- Assuming a country missing from the list is automatically barred. The clause provides other exceptions, including a Government determination under (c)(5), so check the exceptions before drawing a conclusion.
Related provisions
| Provision | Role, as of 2026-10-29 |
|---|---|
| DFARS 225.003, “Qualifying country” | Defines the term and names the 28 countries. |
| DFARS 252.225-7009(b) | Requires specialty metals in delivered items to be melted or produced in the United States, its outlying areas, or a qualifying country. |
| DFARS 252.225-7009(c)(4) | Excepts items manufactured in a qualifying country. |
| DFARS 252.225-7009(c)(5) | Excepts specialty metals the Government determines cannot be acquired in satisfactory quality, sufficient quantity and the required form from those sources. |
FAQ
What are the DFARS compliant countries?
No official list uses that name. The closest official list is the 28 qualifying countries in DFARS 225.003, shown above, which the specialty-metals clause 252.225-7009 uses.
What are the DFARS countries?
Australia, Austria, Belgium, Canada, Czech Republic, Denmark, Egypt, Estonia, Finland, France, Germany, Greece, Israel, Italy, Japan, Latvia, Lithuania, Luxembourg, Netherlands, Norway, Poland, Portugal, Slovenia, Spain, Sweden, Switzerland, Turkey and the United Kingdom, as listed in DFARS 225.003 on 2026-10-29.
Does being a qualifying country make a company DFARS compliant?
No. The status belongs to the country and rests on a reciprocal defense procurement agreement. Company compliance depends on the clauses in each contract.
Is the qualifying-country list the same as CMMC eligibility?
No. CMMC is a cybersecurity program that attaches to contractors and their systems. See the CASRAI guide on DFARS 252.204-7021.
Sources
- DFARS Part 225, Foreign Acquisition, section 225.003 definitions, acquisition.gov, checked 2026-10-29.
- DFARS 252.225-7009, Restriction on Acquisition of Certain Articles Containing Specialty Metals, acquisition.gov, checked 2026-10-29.








