Intro to Defense Manufacturing Compliance: What Program Leaders Actually Need to Know

One non-compliant supplier in a defense supply chain can cause a ripple effect that impacts everyone involved. That has been, and will always be, the reality when fulfilling government contracts. Not only do the parts need to withstand extreme conditions and meet tolerance requirements, but the paperwork needs to match that level of precision.

The defense sector is heavily regulated by government departments to reduce the risk to U.S. security. But if you’re sourcing manufacturing partners, you’ve likely run into a wall of acronyms like ITAR, CMMC, DFARS, EAR, and more. What’s worse: The documentation on these requirements are typically written by lawyers, for lawyers.

In this article, we’ll break down what these defense manufacturing compliance requirements mean for the person actually running the program. It all applies whether you’re manufacturing UAV components, turbine parts, ground vehicle systems, or any other hardware produced by defense contractors.

Export Controls Are the Foundation

Before jumping into supplier evaluation, you need to know whether your part is export-controlled and by which department. This seemingly simple step changes who can touch your data, which suppliers you can use, and how contracts are written.

International Traffic in Arms Regulations (ITAR)

ITAR compliance, administered by the U.S. Department of State, governs anything designed, modified, or intended for military application.

In other words, if your equipment (or its components) is listed on the US Munitions List (USML), it is ITAR-controlled. All manufacturers who participate in creating this equipment must register with the Directorate of Defense Trade Controls (DDTC).

Export Administration Regulations (EAR)

EAR covers components that can be used by multiple industries. For example, commercial drone parts such as GPS modules or batteries can be used for defense applications or private entities. Instead of being governed by ITAR, they fall under the EAR.

How do you know if your part is dual-use? The Bureau of Industry and Security (BIS) publishes a Commerce Control List that classifies parts that fall under this requirement.

Many defense companies will choose to get a commodity jurisdiction from the DDTC or classification determination through the BIS early in the process. This step can save many hours and headaches later in the process.

Cybersecurity Compliance

If your program touches any Controlled Unclassified Information (CUI), which most defense programs do, then your manufacturers are required to hold CMMC certification, which stands for Cybersecurity Maturity Model Certification.

CMMC compliance is structured in tiers, with the requirements scaling based on the sensitivity of the technical data a defense contractor will handle.

The level most relevant to defense sourcing decisions is Level 2. It’s the most common requirement for Tier 1 and Tier 2 defense suppliers, and it requires full implementation of all 110 cybersecurity controls outlined in the National Institute of Standards and Technology’s special publications (NIST SP 800-171), plus an audit by a Third Party Assessment Organization (C3PAO).

These controls demonstrate that any organization handling CUI has the ability to restrict who can access that information, store it securely, and quickly report cyber incidents.

CMMC Level 2 was set to become mandatory in November 2026, but has recently been suspended pending a 60-day review from the U.S. Department of Defense. Third-party assessor capacity and the hefty internal investment to achieve compliance have made the November deadline difficult to achieve. For now, suppliers can complete a self-assessment.

Even though things are in review, its safe to assume this requirement won’t be going anywhere for DoD contracts. If Level 2 applies to your program, start scoping suppliers now so when requirements are in effect, you won’t be left scrambling.

Contracting Compliance

While export controls and cybersecurity gain the most attention, there are additional table stakes to becoming a defense supplier.

**SAM.gov registration:** Your company must be registered here to start doing business with the federal government.

A CAGE code: A Commercial and Government Entity code is a five-character identification number assigned to businesses and organizations that do business with the U.S. federal government. Registering with SAM.gov is the first step to receiving a CAGE code.

There are also a few pieces of legislation that may impact your program. It’s worth familiarizing yourself with these acts:

• Buy American Act and the Trade Agreements Act. Both restrict buying and/or selling components with foreign sources depending on the contract type.
• Section 889. May prohibit certain Chinese telecom and surveillance equipment anywhere in your supply chain.
• Section 5949. Can ban certain Chinese-sourced battery cells in DoD-procured systems. This requirement begins in October 2027.

Quality Certifications

Beyond the legal compliance sit the quality certifications that help you understand how a supplier runs their shop – and which components they’re equipped to produce.

ISO 9001 is the foundation of quality control standards. In practical terms, it means a supplier’s quality isn’t dependent on any one person’s memory or habits. It demonstrates the shop has the documented processes, traceability, and corrective action to produce quality parts at scale. Their certification status also tells you a third-party auditor has verified all their claims against reality.

AS9100 builds on ISO 9001 with aerospace-specific requirements. It is typically written explicitly into a contract, especially for primes. If your program includes aerospace components, you’ll need to look for an AS9100-certified supplier.

Finding the Right Suppliers for Your Program

Aerospace and defense manufacturing compliance is never something to hold lightly. It stacks together export controls, cybersecurity requirements, and quality audits that all hold equal weight. If one, or many, are overlooked, your program holds a growing level of risk.

Verifying that each supplier in your supply chain upholds the precision each standard requires will minimize risk for everyone involved.

Firstar is a precision CNC contract manufacturer based in Brunswick, Ohio. Our machining shop holds ISO 9001:2015 certification, CMMC Level 2 (C3PAO Verified), JCP eligibility, and ITAR registration. We support customers across the defense industrial base, producing parts for engine turbines, rugged communications, munition bodies, and more.

We run our shop floor to industry-leading standards. If your program needs a precision manufacturing partner who can speak to compliance, risk management, engineering complexity, and lead times in the same conversation, we welcome the opportunity.

Qualify Firstar for your defense program. Reach out to us for a quote on your parts.