ITAR and FAR/DFARS flow-downs.
What your prime contract requires has to reach your suppliers. We build a clause matrix from your contract, map each clause to the suppliers it applies to, and write it into your terms and purchase orders.
- 4contract vehicles: FFP, IDIQ, CPFF, OTA
- 7defense programs supported
- 200+active suppliers in an aerospace and defense base
From our founder’s operating roles. Not client results.
Where ITAR and FAR/DFARS flow-downs fail.
Flow-down gaps show up as boilerplate terms, missed dollar thresholds, uncontrolled technical data, and suppliers who never acknowledged the clauses.
Boilerplate terms
One generic clause list goes on every purchase order, whether the supplier machines parts, sells hardware, or provides a service.
Missed thresholds
Clauses that apply only above a dollar value or to certain supplier types are flowed to everyone or to no one.
Export-controlled data
Drawings and specifications under ITAR go out to suppliers, including foreign ones, before anyone confirms who may receive them.
No acknowledgement
Suppliers never confirm they accept the flowed clauses, so there is no record when an auditor or the prime asks.
How we build a flow-down clause matrix.
Every clause in the prime contract, mapped to the suppliers it reaches and the purchase order language that carries it.
- Input
- Prime contract or subcontract, its clause list, and any customer quality and terms attachments
- Matrix
- Each clause mapped to supplier type, commodity, and dollar threshold, following the clause’s own flow-down rule
- Cybersecurity
- Safeguarding covered defense information and cyber incident reporting (DFARS 252.204-7012), NIST SP 800-171 and the DoD assessment clauses (252.204-7019 and 7020), and CMMC (252.204-7021) where your contract carries it, for suppliers that handle that information
- Export control
- ITAR under 22 CFR parts 120 to 130: supplier DDTC registration status, export authorization before technical data is shared, plus export-control marking on the data you send
- Material
- Specialty metals restrictions and Buy American requirements, where the contract carries them
- Electronics
- Counterfeit electronic parts avoidance and sources of electronic parts (DFARS 252.246-7007 and 7008), led by original manufacturers and authorized distributors
- Warranty
- Supplier warranty terms matched to what you owe your customer
- Output
- Purchase order clause sets by supplier type, inside your terms and conditions framework
- Record
- Supplier acknowledgement of flowed clauses, kept in the supplier file
How it works.
Read
Pull the clause list from each prime contract and subcontract, and note which clauses reach suppliers and under what conditions.
You receive: Clause inventory by contract
Map
Build the clause matrix by supplier type, commodity, and dollar threshold, and flag suppliers that handle covered defense information or ITAR technical data.
You receive: Flow-down clause matrix
Write
Add clause sets to your terms and conditions framework and purchase order templates, so buyers select the right set instead of editing by hand.
You receive: Purchase order clause sets and templates
Confirm
Collect supplier acknowledgements, record export and cybersecurity status in each supplier file, and update the matrix when a contract changes.
You receive: Supplier acknowledgement log
From operating experience.
- A terms and conditions framework with contract-specific flow-downs for cybersecurity, ITAR, FAR/DFARS, and warranty clauses.
- Compliance kept with AS9100, ISO 9001, Nadcap, and DCMA/DCAA requirements across FFP, IDIQ, CPFF, and OTA contract vehicles.
- Materials and components sourced for F-35A/C, F-18, V-22, CH-53K, B-52, B-1, and LAU-116B/A contract requirements.
Our founder delivered these results while running supply chain organizations between 2017 and 2021. They are operator results, not client results. See all results
What you receive.
- Clause inventory for each prime contract and subcontract
- Flow-down matrix by supplier type and dollar threshold
- Purchase order clause sets inside your terms and conditions
- Supplier acknowledgement form and log
- List of suppliers that handle covered defense information or ITAR technical data
- Flow-down requirements tied to your AS9100 purchasing controls
Standards, contracts, and systems our founder has worked within
- ITAR
- FAR/DFARS
- BAA clauses
- FFP
- IDIQ
- CPFF
- OTA
- DCMA and DCAA
- Clause matrix
ITAR and FAR/DFARS flow-down questions.
Is this legal advice?
No. We work alongside your contracts team and legal counsel on the supply chain side of flow-downs. We do not give legal advice or rule on how a clause applies, and your attorney approves the final language.
Does every clause in the prime contract flow to every supplier?
No. Many clauses state their own flow-down rule, by dollar value, supplier type, or whether the item is commercial. Flowing everything to everyone adds cost and supplier pushback. Flowing too little leaves you exposed.
Which suppliers need DFARS 252.204-7012?
Suppliers whose work involves covered defense information, such as controlled drawings or technical data, or that provide operationally critical support. They must protect that information under NIST SP 800-171 and report cyber incidents. We identify which suppliers fall in scope so the clause reaches them.
Can we send ITAR drawings to a foreign supplier?
Not until export authorization, such as a license or an exemption, is in place. Releasing ITAR technical data to a foreign person is an export. We flag these suppliers early so your export compliance lead and counsel can decide.
Do flow-downs apply to commercial item suppliers?
Fewer of them. Many FAR and DFARS clauses are limited or not required in subcontracts for commercial products and commercial services, but some, such as DFARS 252.204-7012 where covered defense information is involved, still apply. The matrix records which rule each clause follows.
How do you keep flow-downs current when contracts change?
Each contract modification is checked against the matrix. New or changed clauses update the clause sets, and affected suppliers acknowledge the change.
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