First Article Testing on DLA Contracts: How to Evaluate the Requirement

First Article Testing gives the government evidence that a contractor can furnish a product that conforms to the contract requirements. It can affect price, delivery, production risk, and automated-award eligibility. The actual impact comes from the solicitation, not a universal cost or calendar estimate.

FAR Subpart 9.3 requires the contracting officer to consider delivery time, cost, government risk, and less costly quality-assurance methods before imposing First Article Testing. FAR also identifies situations where FAT may be appropriate, including a new source, a changed process or specification, a long production break, a prior product problem, or the need for an approved manufacturing standard.

The solicitation defines the test

The contract can assign testing to the contractor or the government.

• FAR 52.209-3 applies when the contractor performs the first-article test. The solicitation fills in the number of units, test-notice period, report deadline, government response period, and reporting destination.
• FAR 52.209-4 applies when the government performs the test. The solicitation fills in the unit quantity, delivery deadline, test facility, government response period, and acceptance characteristics.

FAR 9.306 requires the solicitation to state the performance characteristics, test requirements, required data, relationship between the first article and production quantity, and delivery schedule. A supplier cannot estimate the job responsibly from the letters "FAT" alone.

Production before approval is a risk decision

The original version of this article said full production always waits until first-article approval. The FAR rule is more precise.

Under FAR 9.305 and the basic clauses at FAR 52.209-3 and 52.209-4, acquiring material or starting production before approval is normally at the contractor's sole risk. The contracting officer can use Alternate II to authorize specified material purchases or limited production before approval when necessary for the delivery schedule.

Read the clause and any alternate included in the contract. Starting early without the required written authorization can expose the contractor to costs that are not allocable to the contract for progress payments or a convenience termination.

DLA treats FAT quotations as manual evaluations

The current DLA Master Solicitation for Automated Simplified Acquisitions, Revision 105, says solicitations with FAT or Production Lot Testing requirements are not candidates for automated evaluation or award. The quotations are manually evaluated and manually awarded.

For government-performed FAT, Revision 105 says the contracting officer applies an evaluation factor reflecting the government's testing cost. Manual evaluation also follows the factors stated in the solicitation. A supplier should not apply the automated-award price logic to a FAT RFQ.

Price the exact FAT structure

The current DLAD Procurement Notes, effective 2026-07-17, includes Procurement Note E08 for solicitations and awards where FAT applies.

E08 separates two pricing structures:

1. If the solicitation has no separate FAT contract line item, the offeror includes the FAT cost and risk in the production line-item price.
2. If the solicitation has a separate FAT line item, the offeror places FAT cost and risk in that line item and excludes FAT-related cost from the production line-item price.

E08 also says the FAT and production prices must be fair and reasonable and not materially unbalanced. Procurement Notes E09 and E10 provide additional information for contractor-performed and government-performed FAT.

This is why a single number for FAT cost is not a useful shortcut. Build the estimate from the actual sample quantity, test procedure, laboratory or government-testing arrangement, reporting work, destructive-test risk, delivery schedule, and rework exposure in the solicitation.

FAT waivers are discretionary and evidence-based

FAR 9.306 requires solicitations to tell offerors that FAT may be waived when identical or similar supplies have previously been delivered by that offeror and accepted by the government. The clauses at FAR 52.209-3 and 52.209-4 let the offeror request a waiver, but they do not promise one.

DLA Procurement Note E08 gives the DLA-specific request path. The offeror submits the request to the contracting officer and documents prior accepted performance, including contract identifiers and the item previously furnished. If the prior item is similar rather than identical, the offeror explains why that experience demonstrates it can produce the current item without a new first-article test.

There is no single universal DLA FAT-waiver form stated in FAR 9.3 or Procurement Note E08. A form used by one engineering center or program should not be presented as the agency-wide route unless the solicitation or contracting officer directs its use.

A prior approval also does not create permanent waiver status. E08 allows the contracting officer to require an additional first article after a major technical-data change, a production lapse longer than 90 days, or a change in manufacturing facility, process, material, drawing, specification, or source of supply.

Evaluate FAT with contract-specific inputs

1. Test responsibility: Is FAT performed by the contractor or the government?
2. Acceptance basis: What characteristics, procedures, reports, and approval authority are stated?
3. Units and disposition: How many units are required, and are they consumed, returned, retained, or eligible for the production quantity?
4. Schedule: What are the first-article delivery or report deadline, government review period, and production delivery dates?
5. Pricing: Is FAT a separate line item, and what testing or evaluation factors will the government add?
6. Early production: Does the contract include written authorization under Alternate II, or would early work remain entirely at contractor risk?
7. Waiver evidence: Can you document identical or similar supplies previously accepted by the government, and does the contracting officer agree that E08's criteria are met?
8. Demand case: Does documented award history support recovering the qualification, test, and carrying costs at an acceptable risk?

The last question is a commercial judgment, not a regulatory conclusion. A successful FAT on one award does not guarantee recurring demand, a future waiver, or a particular margin.

Request a review of your DLA award record

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FAT requirements live inside the solicitation’s codes and clauses. The free DIBBS Academy teaches how to read a DIBBS solicitation field by field.

Frequently asked questions

How much does First Article Testing cost on a DLA contract?

There is no universal amount. Use the FAT line-item structure, sample quantity, test method, facility, reporting requirement, schedule, destructive-test exposure, and rework risk in the solicitation. DLA Procurement Note E08 tells offerors where FAT cost and risk belong in the quoted price.

How long does DLA First Article Testing take?

The solicitation supplies the first-article delivery or report deadline and the government's response period. FAR 9.306 requires a delivery schedule, but it does not set one duration for all products or test programs.

Can First Article Testing be waived?

The contracting officer may waive FAT when the applicable criteria are met. Prior government acceptance of identical or similar supplies can support a request. DLA Procurement Note E08 requires supporting contract and item information, and the decision remains discretionary.

Can production start before first-article approval?

It can, but the basic rule places pre-approval material and production cost at the contractor's sole risk. The contract may use Alternate II to authorize specified early work in writing. Confirm the clause before committing cost.