BABA Quartz Countertops for Federally Funded Multifamily

When covered federal funds are on a multifamily job, countertops stop being only a finish decision. They become a documentation and sourcing decision. Build America, Buy America (BABA) can apply to iron and steel, construction materials, and manufactured products on covered infrastructure projects. Quartz surfaces often fall in the manufactured-products conversation—so GCs and developers need a clear supply path and manufacturer paperwork, not marketing claims.

I am Ken Leitch, Director of Multi-Family Relationships for Majestic Kitchen & Bath / Majestic Surfaces, based in Charleston and focused on Southeast multifamily work. This page covers how BABA, Section 201, and Section 301 show up in quartz planning—and how we help teams source and document lines that have current manufacturer letters. For materials, local fab vs. import, and install logistics, see the multifamily countertops guide.

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What BABA is—and what it is not

Build America, Buy America is a domestic-preference framework tied to the Infrastructure Investment and Jobs Act (IIJA), Pub. L. 117-58, and implemented for federal financial assistance through rules including 2 CFR Part 184. On covered infrastructure projects, certain products incorporated into the work are expected to meet U.S. production standards unless a valid waiver applies.

Official starting points:

Important: Majestic Surfaces / Majestic Kitchen & Bath and I are not “BABA certified.” Compliance is shown with manufacturer documentation for the specific products and manufacturing locations used on your job—not with a fabricator or salesperson badge. Confirm applicability and documentation standards with your project counsel / funding agency.

When BABA matters on multifamily

HUD guidance treats buildings with five or more dwelling units as infrastructure for BABA purposes when covered federal funds apply. Private deals with no covered federal financial assistance are often outside BABA—but layered financing can change the picture. Confirm with your project counsel / funding agency before you lock a quartz path.

  • Ask early whether the award (or any funding layer) triggers BABA or a related domestic-preference rule.
  • If yes, treat quartz as a compliance item in submittals—not a late VE surprise.
  • Align owner, GC, architect, and surfaces vendor on the documentation the agency expects before color selections go final.

Quartz as a manufactured product

Engineered quartz countertops are typically discussed as manufactured products under 2 CFR 184. For manufactured products, domestic preference generally means manufacture in the United States and a domestic component-cost share greater than 55%—confirm the current threshold and cost method with your compliance team. This page is a procurement checklist, not legal advice.

  • Know the brand, series, and SKUs—not just “quartz.”
  • Collect manufacturer letters that address BABA / Buy America Preference for those products and the U.S. plants that make them.
  • Track manufacturing location changes. A letter from last year may not cover a color now produced elsewhere.
  • Keep the paperwork with submittals so closeouts are not chasing documentation mid-install.

Manufacturer letters: Daltile as an example

Compliance is manufacturer-driven. Fabricators and distributors help you obtain and organize letters; they do not replace them.

As an example of the kind of letter project teams should collect: Dal-Tile, LLC provided a letter dated April 18, 2024, from Cathleen Smith, Sustainability and Compliance Engineer at Mohawk, stating that products manufactured at listed U.S. locations—including Dickson, TN (Quartz), plus other tile plants—comply with BABA requirements of IIJA Pub. L. 117-58 §§70901–70941 as mandated in FTA Programs. That letter illustrates format and content. It is not a blanket approval for every Daltile SKU forever, and not every color is U.S.-made, and Daltile is not “Ken’s brand.” Majestic can help source and document lines that have current letters when your finish schedule calls for it. Download an example manufacturer BABA letter (Dal-Tile, April 18, 2024).

  • Letters are dated. Ask for a current letter at bid and again before procurement if the gap is long.
  • Manufacturing locations can change. Confirm the plant named still applies to your colors and thicknesses.
  • Agency expectations can differ. FTA-framed language may or may not match what your HUD (or other) award needs—confirm with the funding agency.

Important note on Daltile (and any brand): A BABA manufacturer letter for U.S. plants does not mean every color in that brand’s book is made in the USA. Some quartz SKUs are imported. On current Majestic One / Daltile quartz pricing notes, examples marked Import include NQ91 Chipped Ice, NQ69 Ash Grey, OQ19 Alpine Winter, OQ82 Calacatta Villa, OQ88 Moon Gaze, OQ86 Calacatta Royale, OQ91 Amazonite, OQ95 Amazonite Gray, and DQ02 Taj Castella. Always confirm country of manufacture for the exact color and thickness on the finish schedule—do not assume “Daltile quartz” equals domestic.

Manufacturer resources

Use manufacturer pages and letters as starting points—then confirm the exact SKU, plant, and letter date for your finish schedule.

Section 201 and Section 301

Even when BABA does not apply, trade measures can still affect quartz cost and lead time.

Section 201

Section 201 covers trade safeguard-style measures that can affect pricing and availability of imported quartz and related surfacing. Exact duty treatment depends on classification, origin, and the measure in effect at entry—do not hard-code a rate into the pro forma from a sales conversation. Build contingency around the possibility that import economics shift during design or early construction.

Section 301

Section 301 is a U.S. Trade Representative enforcement tool. The China Section 301 actions (technology transfer / IP investigation) add extra tariffs on many Chinese-origin goods across tariff “lists.” Official reference: USTR – China Section 301 tariff actions.

For quartz, Section 301 can apply when the merchandise is China-origin under the applicable HTS classification—sometimes in addition to normal duty. Exact rates and any exclusions change; confirm with your importer or broker rather than baking a single percentage into the GMP. Section 301 is separate from BABA, from antidumping/countervailing duty orders on Chinese quartz surface products, and from Section 201/203 safeguard measures on imported quartz surface products.

Together with BABA, these measures push the same decision covered in the local fabrication vs. overseas sourcing section of the multifamily guide: match the supply path to compliance, lead time, and budget—not to habit.

Local fab vs. overseas when compliance is on the table

On private, non-federally-funded jobs, overseas-sourced programs can still fit competitive volume pricing when lot planning and lead times are honest. On covered BABA jobs, the question tightens: can you document U.S. manufacture (and the domestic component test your compliance team applies) for the products you want?

  • U.S.-manufactured quartz lines often simplify BABA documentation when manufacturer letters are current and plant lists match the SKUs.
  • Local fabrication still helps with templates, field changes, and wave releases—even when the slab is domestically manufactured.
  • Overseas / import sourcing may remain viable on non-BABA work, or where a valid waiver applies, but Section 201 / 301 exposure belongs in the cost conversation from day one.

I will not pretend every colorway has a current BABA letter. If a preferred finish cannot be documented, we flag it early and work alternate SKUs with the design team—before models and unit matrices lock.

How Majestic helps without overclaiming

  • Help identify quartz lines manufacturers currently support with BABA-oriented letters.
  • Collect and organize manufacturer documentation for submittals—without calling ourselves “BABA certified.”
  • Price and schedule domestic vs. import paths alongside finish class, edges, and install sequencing.
  • Stay the single point of contact when compliance, cost, and field logistics collide.

What we will not do: invent duty rates, guarantee agency acceptance of a letter, or claim a product is compliant without manufacturer backup for the SKUs and plants on your order.

How to start

Send market/location, unit or building count, whether covered federal funds (or BABA) apply, target quartz brands/colorways, and rough install windows. If you have a finish schedule or manufacturer letter, include it.

Contact Ken · Multifamily countertops guide

FAQ: BABA, tariffs, and multifamily quartz

Is Majestic or Ken Leitch “BABA certified”?

No. Compliance for quartz is shown through manufacturer documentation for the products and U.S. manufacturing locations used on the project. We help source lines and gather current letters; we do not replace the manufacturer’s certification.

Does BABA automatically apply to every apartment community?

No. HUD guidance treats buildings with five or more dwelling units as infrastructure for BABA when covered federal funds apply. Private projects without covered federal financial assistance often are not subject. Confirm with your project counsel / funding agency.

Is a Daltile letter enough for every quartz SKU on my job?

Not by itself. Confirm the letter’s date, the plants listed (for example, Dickson, TN for quartz on the April 18, 2024 Dal-Tile example), and that your colors/thicknesses are covered. Manufacturing locations and letter language can change.

How do Section 201 and Section 301 affect my countertop budget?

They can change landed cost and availability of imported quartz and related inputs. Verify current exposure with purchasing or trade specialists—do not bake a guess into the GMP.

Ken Leitch · Director of Multi-Family Relationships · Majestic Surfaces / Majestic Kitchen & Bath · kenleitch.com