Understanding DFARS, ITAR, CMMC, and Other Regulations

A Guide for Aerospace and Defense Manufacturers

Compliance is a fixed point of entry for aerospace and defense manufacturers; if your company isn’t compliant with or following aerospace regulations and requirements, you cannot compete in the defense industrial base.

Modern aerospace and defense regulations go far beyond basic quality management, and were established in response to increasing cybersecurity threats, the growing complexities of global supply chains, and tenuous geopolitical tensions that create manufacturing uncertainties. Requirements cover everything from cybersecurity, materials sourcing, and quality assurance to supply chain management and export controls.

Primus has always treated compliance requirements as a mandate for doing business – not just a competitive advantage – and this article breaks down the regulations we and every supplier must comply with.

OEMs and Tier 1 suppliers looking for reliable manufacturing partners in the aerospace and defense supply chain can use this article as a guide to understand how each requirement provides quality, security, and risk management.

Quick Reference Guide to Major Aerospace & Defense Compliance Regulations

For suppliers supporting the U.S. Department of Defense (DoD), regulatory compliance goes hand-in-hand with operational excellence and high-quality production.

Aerospace & Defense Compliance at a Glance

Why Regulatory Compliance is Expanding Across Aerospace & Defense Manufacturing

While each regulation enumerated in the above table serves a unique purpose, together they create a framework that creates a comprehensive risk management strategy and guides aerospace and defense manufacturing priorities: 

• Protecting sensitive government and customer information
• Producing high-quality, reliable aerospace and defense parts and assemblies
• Maintaining complete material and process traceability
• Securing manufacturing systems against cyber threats
• Ensuring compliance throughout the global supply chain
• Supporting national security by safeguarding critical technologies

Compliance is more than checking boxes to avoid penalties. Regulations like CMMC are designed to ensure organizations are fundamentally shifting their processes to be in compliance with each requirement, thereby adequately protecting sensitive technologies, information, and products. 

And like CMMC, there are often lengthy compliance runways that allow organizations to meet the requirements in phases or tiers rather than all at once.

Let’s break down the key aerospace and defense regulations that have required manufacturers to shift and adapt their processes to ensure compliance.

The Key Aerospace and Defense Regulations Explained

DFARS: Strengthening Cybersecurity Across the Defense Supply Chain

Software company IFS reports that more than 40% of defense contractors have experienced cyber incidents. To circumvent these risks, the Defense Federal Acquisition Regulation Supplement (DFARS) establishes specific contracting requirements for companies doing business with the Department of Defense. 

Specifically, contractors handling Controlled Unclassified Information (CUI) must adhere to the 110 security controls outlined in NIST SP 800-171, which fall into 14 groups:

• Access Control: Limit system access to authorized users
• Awareness and Training: Train staff on security risks and policies
• Audit and Accountability: Track system events and user actions to maintain an audit trail
• Configuration Management: Control and document hardware and software settings
• Identification and Authentication: Verify the identity of users and devices before granting access
• Incident Response: Plan how to detect, report, and recover from cyber attacks. 
• Maintenance: Perform routine repairs and updates on system components
• Media Protection: Secure physical and digital media holding CUI
• Personnel Security: Screen employees and secure systems when workers leave
• Physical Protection: Limit physical access to facilities and equipment
• Risk Assessment: Identify and evaluate cybersecurity vulnerabilities and risks
• Security Assessment: Routinely test and evaluate security controls
• System and Communications Protection: Secure data during transit and storage
• System and Information Integrity: Protect against malware and unauthorized changes

Dive Deeper: Aerospace & Defense Cybersecurity Risks

DFARS has made cybersecurity an organizational priority for defense manufacturers rather than an IT-related one. 

CMMC: Verification of Cybersecurity Readiness

The Cybersecurity Maturity Model Certification (CMMC) expands upon DFARS with a requirement for third-party validation of cybersecurity practices.  

Defense contractors can no longer self-verify their cybersecurity controls. CMMC provisions require that they demonstrate the implementation and maintenance of specific safeguards.

CMMC also impacts aerospace manufacturers:

• Secure engineering data management
• Controlled access to manufacturing information
• Vendor risk management
• Employee cybersecurity awareness 
• Secure collaboration with customers and suppliers

With 110 baseline practices and 24 additional controls from NIST SP-172, CMMC compliance is often a lengthy process for aerospace and defense organizations. Implementation occurs in three levels and seeks to establish an ongoing commitment to cybersecurity that includes consistent monitoring and regular updates and assessments.

Dive Deeper: Protecting Your IP and Production Data from Breaches and Security Threats

According to cybersecurity firm Radicl, 81% of small-to-medium aerospace and defense manufacturers have started the CMMC compliance process; however only 13% are compliant with Level 1, and 11% are compliant with Level 2. These lagging numbers suggest that aerospace and defense SMBs may struggle to combat the cybersecurity threats that are increasingly targeting this sector.

ITAR: Protection for Sensitive Defense Technologies

The International Traffic in Arms Regulations (ITAR) control the security of defense products, technical data, and services being exported or transferred. In short, anything listed on the United States Munitions List (USML). 

Importantly, ITAR doesn’t just refer to international exports and imports. It also governs access to:

• Technical drawings
• Manufacturing documentation
• Cloud data storage 
• Engineering information 
• Digital communications involving controlled information

Access by foreign nationals to this information also falls under ITAR, and manufacturers supporting defense programs must maintain strict controls over who is accessing ITAR-controlled information and where that information is stored. 

Procurement automation company Cofactr points out that engineering teams are often surprised to learn they must comply with ITAR even if they never export anything.

EAR: Overseeing Items on the Commerce Control List

EAR regulates the dual-use (commercial and military) technologies that have military applications. It is overseen by the Commerce Department and includes items listed on the Commerce Control List, such as:

• Nuclear Materials
• Chemicals, Microorganisms, and Toxins
• Telecommunications and Information Security
• Navigation and Avionics
• Propulsion Systems, Space Vehicles, and Related Equipment

Manufacturers must understand whether a product falls under EAR or ITAR jurisdiction before sharing technical information or exporting parts and assemblies internationally.  

EAR is considered less strict than ITAR because it does allow for what the Eagle Law Group cites as the “De Minimis Rule” – certain levels of U.S. content in foreign-made items deemed insignificant may be exempt from some EAR controls, which is incredibly helpful for startups building global supply chains as they can operate globally without repeatedly requiring permission from the U.S. government.

Proper item classification under EAR does two things: (1) Prevents aerospace and defense manufacturing companies from being in violation of the regulation, and (2) Ensures secure global business operations.

Specialty Metals Clause: Strengthening Domestic Industrial Capabilities

The Specialty Metals Clause is designed to help reduce dependence on foreign sources for critical defense materials. This clause restricts the sourcing of certain specialty metals to a list of approved countries. These metals can include:

• Types of steel
• Titanium
• Nickel alloys
• Zirconium

Because many aerospace and defense manufacturing companies rely on specialty and emerging metals to meet demands for higher performance, lighter weights, and increased durability, this clause has become a critical consideration. Its parameters encompass material certifications, and traceability and product lifecycle documentation requirements.

Dive Deeper: How Emerging Materials in Aerospace Affect Machinability and Design

According to a Discovery Alert article from January 2026, the United States has “concerning dependency” on importing specialty materials essential for national defense and technology. The article cites recent government assessments showing the U.S. has 100% import reliance for 12 critical minerals and 50% or more import reliance for 29 additional materials. 

The Specialty Metals Clause seeks to lower import dependency in an effort to subsequently lower security vulnerabilities.

Counterfeit Electronic Parts Detection & Avoidance: A Supply Chain Impact

Although many precision machining suppliers don’t manufacture electronic components, they may produce parts or assemblies that require them. In these cases, complete supply chain integrity under the Counterfeit Electronic Parts Detection & Avoidance System (CEPDAS) becomes critical. 

CEPDAS, which is housed under DFARS, requires manufacturers to do three things:

1. Trace Parts: Every part must be tracked, with proof of where it was made and where it came from. 
2. Test Parts: Using X-rays or electrical tests, parts must be checked for authenticity. 
3. Share Fakes: Fake or suspected fake parts must be reported to databases like the Government-Industry Data Exchange Program (GIDEP)

Counterfeit electronic parts are actually a tremendous challenge in modern supply chains that can pose serious safety, reliability, and national security risks, especially in the aerospace and defense manufacturing space. 

Reducing these risks under CEPDAS requires contractors to establish and maintain an ongoing counterfeit detection and avoidance program to help stop fake parts from entering the supply chain. Processes include:

• Qualifying every supplier
• Performing traceability verification of every part
• Proper training on CEPDAS and testing procedures
• Inspection and authentication testing for each part 
• Monitoring counterfeit alerts and reporting any instance of counterfeit parts

Foreign Ownership, Control, or Influence: Protecting National Security

Manufacturing companies supporting classified defense work may be subject to Foreign Ownership, Control, or Influence (FOCI) requirements, which evaluate whether a company’s operations are vulnerable to foreign influence in a way that could create national security risks. 

In plain English, contractors and subcontractors handling classified information must prove they are free from foreign influence. Additionally, aerospace or defense firms must disclose if they have foreign owners, investors, board members, or supply-chain dependencies in order to secure contracts. 

The Office of Industrial Base Growth explains what businesses must do to comply with FOCI and mitigate risk:

Implement Contract & Relationship Management Policies: Includes reviewing contracts and validating relationships or affiliations; ending partnerships and cancelling technology licensing agreements with entities affiliated with a foreign country of concern; and transferring voting rights away from problematic foreign shareholders to a U.S.-based citizen. 

Establish Personnel and Governance Requirements: Require covered individuals to resign from positions or cease foreign affiliations deemed problematic by a risk-based security review; remove problematic foreign board members; require all covered individuals and management personnel to complete insider risk awareness training; require increased frequency of reporting by covered individuals through progress report forms.

Financial and Supply Chain Management: Reduce the percentage of problematic foreign investment in the business; limit foreign supply chain dependence; remove problematic foreign debt and foreign financial obligations.

Federal Acquisition Regulations: Governing Federal Procurement

While DFARS adds defense-specific requirements for federal procurement, the Federal Acquisition Regulations (FAR) outline expectations related to ethics, contracting, documentation, reporting, supplier responsibility, and overall contract performance. 

Any manufacturer supporting federal contracts must integrate FAR requirements into business processes alongside industry-specific regulations.

AS9100: The Foundation of Aerospace Quality

Cybersecurity threats are often mentioned first in compliance discussions, but quality management remains an equally critical factor. 

AS9100 is the internationally-recognized quality management standard developed specifically for manufacturers in the aerospace industry. It is an extension of ISO 9001 as it introduces additional requirements for risk and configuration management, product safety, counterfeit parts prevention, continuous improvement, and supplier management. 

There are 4 primary ways high-precision aerospace manufacturers benefits from AS9100:

1. Consistency, Traceability, and Repeatability: AS9100 requires documented, repeatable processes from design through delivery to ensure each part meets the same high standard.
2. Risk Management & Safety: AS9100’s Risk-Based Thinking provision ensures proactive identification and mitigation of potential hazards during the design, manufacturing, inspection, and delivery processes.
3. Customer Confidence & Global Acceptability: AS9100 supports supply chain access, business credibility, and market growth as it demonstrates compliance with aerospace industry standards and regulatory expectations.
4. Operational Excellence: By reducing waste and minimizing defects manufacturing efficiency and part performance improves.

Dive Deeper: How AS9100 Certification Sets the Standard in Aerospace Manufacturing

NADCAP: Validating Critical Manufacturing Processes

The National Aerospace and Defense Contractors Accreditation Program (NADCAP) provides accreditation for special manufacturing processes that can’t be fully verified through final inspection alone. 

Processes commonly covered under NADCAP can include:

• Materials Testing
• Heat Treating
• Chemical Processing
• Weldings & Coatings
• Non-Destructive Testing

Achieving accreditation under NADCAP demonstrates that a manufacturer’s critical processes consistently meet demanding aerospace requirements, reducing risk for customers and improving confidence throughout the supply chain.

Dive Deeper: Manufacturing for Mission-Critical Performance

How Aerospace & Defense Suppliers Are Adapting to a Tighter Regulatory Environment

Bain & Company recently reported that US aerospace and defense companies are targeting production increases up to six times the current rate – the fastest pace in decades. 

Despite that rapid growth, the article notes that supply chain constraints hamper product delivery in nearly 90% of programs analyzed, outranking workforce shortages, budget constraints, and engineering timelines as other obstacles.

It’s clear that as the industry expands and demands continue to grow, compliance across all regulations – from quoting and supplier selection to machining, inspection, documentation, cybersecurity, and delivery – will contribute to a more seamless production process. 

Leading aerospace and defense manufacturers are wise to treat these regulations as a holistic compliance strategy that connects their quality systems, digital infrastructure, and workforce. 

Improving operational efficiency, reducing risk, and increasing customer loyalty now relies on investments in strategic regulatory areas:

• Expanding cybersecurity programs
• Strengthening supplier qualification and material traceability
• Digitizing quality documentation and production records
• Increasing employee training around export controls and secure data handling
• Conducting regular internal audits and risk assessments
• Building compliance into manufacturing workflows rather than treating it as a final checkpoint

While compliance is no longer a stand-out competitive differentiator, non-compliance is a deal-breaker. OEMs and primes are placing emphasis on selecting manufacturing partners that demonstrate technical capability and regulatory maturity. 

Not to mention, demonstrating continued adaptability as the landscape changes only proves a company’s ability to deliver quality in this mission-critical, high-complexity, high-precision market.

Work with a supplier that meets and exceeds all aerospace and defense compliance requirements.