Berry-compliant closures for covered Berry end-products — the second-source position you can cite at audit.
When DoD procures a Berry-covered article (a uniform, body-armor carrier, tent, or coated fabric), every component that ships with it — including the zippers, the hook-and-loop tape, and the snap fasteners — is subject to Berry. Redoubt issues a per-lot Berry-compliance statement with every shipment, naming the end-product, the component percentage test, and any specialty-metals or COTS carve-outs.
What the Berry Amendment actually says.
The Berry Amendment (10 U.S.C. § 4862) restricts DoD purchases of covered clothing, textile, and footwear articles to articles in which all component fibers, fabrics, and other materials were grown, reprocessed, reused, or produced in the United States. The statute applies directly to DoD acquisitions and flows through to subcontractors in the supply chain.
The practical test is the domestic end-product. For clothing and individual textiles, a domestic end-product is one that is substantially transformed in the United States and is itself composed of components that were produced there. For end-products that are not commercially-discrete articles (such as coated fabrics or tent panels), DoD's class-deviation DFARS 252.225-7012 permits a component-percentage test: a stated dollar-value share of the components supplied may be foreign, with the remainder required to be domestic.
Two implications matter for closures. First, the end-product test governs the component: if the end-product is foreign, the closure is foreign by Berry definition and irrelevant to compliance. Second, the component-percentage test is the lever contractors use when a fully domestic bill of materials is impractical — and the lever that has to be reported, line by line, in a Berry-compliance statement.
When does Berry attach to a zipper?
Walk the six steps below to decide whether a given closure is in scope for a Berry-compliance statement on the next lot. The path from step 1 to step 6 is the same path a DoD contracting officer or DCMA reviewer walks in reverse.
- 01
Is the end-item a covered Berry article?
Berry attaches when DoD acquires (directly, by subcontract, or through a prime) any clothing, textile, or footwear end-product listed in 10 U.S.C. § 4862(a)(2)-(3) — most visibly, uniforms, body armor, tentage, and coated fabrics.
- 02
Is the closure (zipper, hook-and-loop, snap) a component of that end-item?
A zipper, hook-and-loop tape, or snap fastener sewn or bonded into the Berry end-product is treated as a Berry component, not a COTS article. The end-product test governs the component.
- 03
Has the end-product been substantially transformed outside the United States?
Berry is satisfied only when the end-product is "grown, reprocessed, reused, or produced in the United States." If the end-product is a foreign end-product, the component is foreign by Berry definition and out of scope for a compliance statement.
- 04
Do any specialty-metals or specialty-fiber triggers apply?
Even when the end-product is a domestic end-product, components containing specialty metals (e.g., stainless or alloy steel melt/pour performed outside covered countries) or specialty fibers may still be non-compliant — the clause-by-clause statement catches these.
- 05
Does the COTS exception actually apply?
Commercial-off-the-shelf articles (COTS) are exempt as end-products — but a zipper purchased as a COTS article and sewn into a Berry end-product is a Berry component, not a COTS end-product. The exception rarely reaches closures.
- 06
Document the chain — and request a Berry-compliance statement when you order.
For each lot, request a written Berry-compliance statement that names the end-product, the component percentage test result, and any carve-outs. We issue these per shipment on request.
How to read a Berry-compliance statement.
A Berry-compliance statement is not a generic RoHS / REACH attestation. Each clause below corresponds to a paragraph in the statement Redoubt issues — read them in order, and you can reconstruct the full Berry reasoning for the lot.
End-product country of origin
Names the specific end-product the component will be sewn into (e.g. "Army Combat Uniform trouser, NSN XXXX") and declares the end-product to be a domestic end-product under 10 U.S.C. § 4862.
Component percentage test
For end-products that are not commercially-discrete articles (e.g. tents, coated fabrics), Berry permits a dollar-value component-percentage test. The statement reports the percentage of domestic components actually supplied and confirms it satisfies the threshold.
Foreign-end-product carve-out
Where a percentage of components is permitted to be foreign, the statement distinguishes those line items so the contractor can isolate the Berry-compliant portion of the shipment for invoicing / traceability.
Specialty-metals carve-out
Identifies whether the component contains specialty metals (stainless, alloy steel, etc.) and confirms melt/pour performed in the United States or another covered country — required even when the end-product is otherwise domestic.
COTS exception
Where a component genuinely qualifies as a commercial-off-the-shelf article of supply sold in substantial quantities in the commercial marketplace, the statement cites the COTS exception and explains why it applies (so reviewers do not have to reverse-engineer the call).
Lot linkage and traceability
The statement is tied to a specific lot number and shipment, so a quality escape can be traced back to the statement — not just the article.
Related documentation.
DFARS fastener systems
Specialty-metals compliance, MIL-SPEC traceability, and procurement-ready intake for defense fastener contracts.
See the DFARS catalogTechnical resources
Alloys, torque / tensile references, thread standards, and installation prep guides for procurement, engineering, and QA teams.
Open technical resourcesRequest a Berry Compliance Statement.
Tell us the program, the end-product (NSN or nomenclature), the expected lot size, and the target delivery window. Our defense procurement team will respond within one business day with the statement template, the component-percentage test we will run, and a confirmation of the documentation chain for your shipment.
Or request a material sample — samples ship ahead of the formal statement so engineering can evaluate first.