Navigating BABA Compliance: Sherwin-Williams Coating Solutions for Water Infrastructure Projects

For stakeholders in the water and wastewater industry, BABA has become a central point of focus. It requires that iron, steel, manufactured products and construction materials used in federally funded infrastructure projects be produced in the United States. While the goals of strengthening domestic supply chains and supporting American jobs are clear, the path to compliance can be complex.

This article provides an in-depth look at BABA compliance for water infrastructure projects, with practical insights, documentation requirements and Sherwin-Williams’ portfolio of BABA-compliant protective coatings and linings. By the end, engineers, contractors and procurement leaders will have a clear roadmap to navigate compliance and protect both assets and taxpayer investments.

Understanding the Build America, Buy America Act (BABA) 

BABA is part of the larger IIJA framework, which invests billions into modernizing U.S. infrastructure—from roads and bridges to broadband, energy and water systems. Specifically, BABA works to:

• Strengthen domestic manufacturing by requiring U.S.-made materials.
• Support American jobs by channeling taxpayer dollars back into U.S. supply chains.
• Ensure accountability by demanding thorough documentation, verification and oversight from grantees, subrecipients and suppliers.

The ultimate goal: build resilient, sustainable infrastructure while maximizing the economic benefit to American workers and manufacturers.

BABA Requirements for Water Infrastructure Projects 

The Environmental Protection Agency (EPA) is the lead agency implementing BABA for water-related projects. That means certain projects must comply with strict sourcing and documentation standards, including projects like:

• Drinking water treatment plants
• Wastewater treatment facilities
• Distribution and collection systems
• Storage tanks
• Transmission through the use of pipelines

Material Categories Covered

According to the EPA’s compliance framework, three major material categories are impacted:

1. Iron and Steel

• Must be produced in the U.S.
• Includes all manufacturing processes.

2. Manufactured Products 

• At least 55% of total component costs must be mined, produced or manufactured in the U.S.

3. Construction Materials 

• Must be manufactured in the U.S.
• Includes the final point of manufacturing.

Documentation Requirements 

To meet compliance, project stakeholders must provide thorough documentation, including:

• Certification letters from manufacturers verifying domestic origin.
• Invoices and packing slips linking materials to specific projects.
• Manufacturer declarations confirming the percentage of U.S.-sourced components.
• Market research documentation if U.S.-made alternatives are unavailable.

This paperwork must be available for audits and inspections. Non-compliance risks funding delays or loss of federal dollars.

The Role of BABA Compliance Oversight and Enforcement 

The EPA has built multiple layers of oversight into its implementation process:

• Grantees: Ensure compliance across all projects.
• Subrecipients: Follow BABA guidelines and submit proper documentation.
• Contractors: Adhere to standards and maintain verifiable records.

Enforcement mechanisms include:

• Site visits by EPA representatives.
• Desk reviews of submitted documentation.
• Random audits to verify compliance across projects.

Best Practices for Achieving BABA Compliance 

For engineering firms, contractors and municipalities, compliance is not just about ticking regulatory boxes—it’s about embedding best practices into project management.

Training and Education 

Provide regular training sessions for subrecipients, contractors and procurement staff to ensure that everyone understands BABA requirements and stays up to date with evolving guidelines.

Documentation Management 

Organize certifications, invoices and declarations systematically. Using digital platforms to centralize compliance records can streamline audits and site inspections.

Open Communication 

Foster transparent communication across all stakeholders—sharing compliance expectations early in the project lifecycle to avoid costly delays later.

Sherwin-Williams: Supporting BABA Compliance with Protective Coatings

While compliance may seem daunting, manufacturers like Sherwin-Williams have stepped up to provide practical solutions. Our Protective & Marine division offers a robust portfolio of BABA-compliant coatings and linings specifically designed for water and wastewater infrastructure.

These products not only meet domestic sourcing requirements but also deliver long-term durability, corrosion protection and cost-efficiency.

Sherwin-Williams BABA-Compliant Products

Corobond® 100 

• Two-component, low-viscosity epoxy primer/sealer.
• Provides excellent surface penetration and adhesion for concrete and steel.

Corothane® I Galvapac 1K 

• Single-component zinc-rich primer.
• Offers exceptional corrosion resistance and easy application.

Macropoxy® 646 Fast Cure 

• High-solids, fast-drying epoxy mastic.
• Widely used in water treatment facilities for rapid return-to-service.

Macropoxy® 5500LT

• High-performance polyamide epoxy lining.
• Ideal for potable water storage tanks.

Sher-Glass® FF 

• Glass flake reinforced epoxy coating.
• Delivers durability in high-abrasion, chemical-exposure environments.

Dura-Plate® 6000 & Dura-Plate 6100

• 100% solids epoxy linings.
• Excellent for immersion service and severe wastewater conditions.

Corothane® I HS Aliphatic Finish

• Moisture-curing urethane finish.
• Superior weathering and UV resistance.

Acrolon™ 218 HS 

• Fast-drying, aliphatic polyurethane.
• Outstanding gloss and color retention for exterior structures.

Hi-Solids Polyurethane & Hi-Solids Polyurethane 250 

• Aliphatic polyurethane finishes.
• Provide chemical resistance and long-term weather protection.

Why These Products Matter 

Choosing Sherwin-Williams coatings helps project teams:

• Ensure compliance with BABA regulations.
• Reduce risk of project delays due to sourcing or documentation issues.
• Protect critical infrastructure assets against corrosion, abrasion and environmental stressors.
• Support sustainability by extending the service life of water infrastructure systems.

The Bigger Picture: Why BABA Matters 

Strengthening U.S. Supply Chains 

By requiring domestic sourcing, BABA helps rebuild and stabilize critical supply chains. This reduces reliance on international imports and supports resiliency in times of global disruption.

Boosting American Jobs 

Every project that uses American-made materials contributes to job creation in steel mills, manufacturing plants and logistics operations across the country.

Protecting Taxpayer Investments

When materials are sourced domestically and supported by rigorous quality standards, infrastructure projects are more likely to last longer, reducing the need for costly repairs and replacements.

Sherwin-Williams: A Partner in BABA Compliance

BABA compliance may seem like a regulatory challenge, but it is also an opportunity to strengthen domestic industry, protect taxpayer dollars and build resilient water systems for generations to come.

Sherwin-Williams is ready to support engineers, contractors and project owners with a portfolio of BABA-approved coatings for water and wastewater infrastructure, documentation support to simplify compliance processes and expert guidance through dedicated infrastructure specialists. By leveraging Sherwin-Williams’ expertise and solutions, stakeholders can confidently navigate BABA requirements and deliver projects that protect both infrastructure and communities.

To learn more about BABA compliance for water infrastructure projects, contact Sherwin-Williams today.