Color is a component. When a boot, a pack, or a textile assembly is bought with Department of Defense funds under the Berry Amendment, the parts that go into it have to be domestically produced, and that includes the color. P.A.T. Products matches and produces color in the United States, which makes our liquid color a domestically produced component for Berry programs. Here is what that means in practice, and where the line sits.
What the Berry Amendment requires
The Berry Amendment (10 U.S.C. 2533a, recodified as 10 U.S.C. 4862) requires the Department of Defense to buy certain items from domestic sources. The covered list is specific and includes footwear and textiles, along with food, fabrics, fibers, yarns, tents and tarpaulins, hand and measuring tools, and flags. For these items the standard is strict: the production process is meant to be performed in the United States, from raw material through component manufacture to final assembly. A covered end item is only as domestic as the inputs that go into it, so the components matter, not just the final stitch.
Where color fits
Footwear and textile assemblies are colored somewhere in the build. An outsole cast in polyurethane is colored before it cures. A coated fabric, a foam, or a molded part carries color too. If the end item has to meet Berry, the color that goes into it should itself be domestically produced. Color sourced offshore is a foreign input inside a part that is supposed to be domestic, and that is exactly the kind of detail an audit looks for.
That is the gap our color fills. We match and produce liquid color in the United States, so it stands as a US-made component in a Berry build.
What qualifies, and what we are careful about
Here precision matters, because a procurement officer will check.
Our liquid color dispersions are matched and produced in the United States. They are the format for cast polyurethane, PU and epoxy systems, flexible PVC, and foam, which covers a large share of footwear and textile color. For those, our color is a domestically produced component, and we will put that in writing.
Masterbatch is a different case. A masterbatch is pigment compounded into a base resin, and that resin, a TPU or another thermoplastic, may be imported. Because the Berry standard looks at the whole production chain, a masterbatch follows the country of origin of its carrier resin rather than our compounding step. So we do not make a blanket Berry claim on masterbatch. If your part is a molded or extruded thermoplastic and the program requires domestic content, tell us the resin and we will work out what can be supplied on a domestic basis.
Drawing that line is the point. A vendor who calls every product Berry compliant is a vendor whose paperwork will not survive an audit.
Documentation
The Berry Amendment runs on manufacturer certification. As the producer of the color, we provide a Berry Amendment statement for our US-made liquid color on request, identifying the product and confirming domestic production. Our color also carries the other compliance a defense or commercial program asks for: REACH, RoHS, and California Proposition 65. FDA 21 CFR food-contact documentation is available for qualifying grades, and Technical and Safety Data Sheets ship with every color.
Matching and supply
The color is matched to your standard, whether that is a Federal Standard 595 chip, a PANTONE or RAL reference, a hex value, or a physical sample. Federal Standard 595 is the reference set most defense color work runs on, and we match to it directly.
Lead time is about one week for color matches and commercial orders. Colors are available in 5 kg, 12.5 kg, and 20 kg pails, drums, and totes. We supply carriers based on low-viscosity plasticizer, polyether polyol, polypropylene glycol, Benzoflex, or vegetable oil, and UV stabilizers, antistats, fluorescent colors, and tints are available.
Working a Berry program
Tell us three things: the color standard, the resin or system the color goes into, and whether the program runs under Berry or another domestic-preference rule. We match the color, confirm it in your system, ship a sample, and provide the Berry Amendment statement for the US-made color. If a part runs in a thermoplastic that needs masterbatch, we say up front what can and cannot be supplied on a domestic basis, so nothing in the paperwork is a surprise later.
See pigments and color