The SBA’s 2025 Non-Manufacturer Rule Update: What Every Small Business Reseller Needs to Know
The Small Business Administration (SBA) just dropped a major clarification on the Non-Manufacturer Rule (NMR), and it’s a big deal for anyone selling products in the federal market. If you’re a small business—especially if you’re chasing 8(a), HUBZone, SDVOSB, WOSB, or general set-aside supply contracts—this update spells out exactly when you need to comply, when you need a waiver, and what could get you disqualified. Here’s what you need to know to stay compliant and competitive.
In Plain English: What Changed
The July 14, 2025, SBA fact sheet finally clears up long-standing confusion around who the NMR applies to and when. In a nutshell:
NMR applies to all socio-economic set-aside or sole-source supply contracts above $10,000—including 8(a), SDVOSB, HUBZone, and WOSB.
For general small business set-asides, NMR only kicks in above the Simplified Acquisition Threshold (SAT)—about $250,000.
The NMR only applies to procurements under supply/manufacturing NAICS codes (or IT VAR code 541519), not services or construction contracts.
IT Value-Added Resellers (ITVARs) get a special size standard (150 employees), but still must follow NMR.
Waivers are possible—either class waivers (for product categories with no small manufacturer) or individual waivers (contract-specific).
Why You Should Care
For many small contractors, NMR is the hidden landmine that can blow up an award—even after you win it. Failing to meet NMR compliance can result in protests, lost contracts, or worse—fraud investigations. With SBA’s increased focus on Made-in-America goals and reducing fraud in programs like 8a certification assistance and disabled veteran government contracts, NMR compliance is now squarely in the spotlight.
This update especially affects:
Small product resellers and value-added resellers (VARs)
Businesses pursuing 8a contracts services
Firms using women business certification or disabled veteran small business certification to access set-aside supply contracts
Anyone working under SBIR Grant Assistance where product delivery is involved
Five Actionable Tips for Small Businesses
Always Check the NAICS Code: If it’s a service contract—NMR doesn’t apply. If it’s a supply/manufacturing contract—you must comply. Use tools like SAM.gov and Dynamic Small Business Search (DSBS) to double-check your contractor NAICS code.
Document Your Supply Chain: SBA will now be scrutinizing ownership, warehousing, or drop-shipping records. Make sure your proposal shows exactly where your products come from and who manufactures them—especially for government contracting certification audits.
Look Up Waivers Before You Bid: Products like laptops and medical supplies often have class waivers. Check SBA’s updated waiver list—if a waiver exists, you can supply from large manufacturers legally. Grant Writing for Nonprofits often overlooks these nuances in product procurement, but you shouldn’t.
Don’t Rely on Sole-Source Safety: Even sole-source awards under 8a contracts services or SDVOSB contracts require NMR compliance. SBA made it clear—sole-source is no shortcut.
Educate Your Team on Industry Hotspots: Sectors like IT hardware, medical devices, and industrial equipment have dynamic waiver statuses. This is especially critical for companies exploring government contracting opportunities in those markets.
Looking Ahead: What’s Next for Small Contractors
This updated NMR guidance is part of SBA’s bigger crackdown on fraud and focus on domestic manufacturing. Expect:
Tighter NMR enforcement in government procurement
More contract audits tied to the government contracting certification process
Less room for error in industries where SBA believes small manufacturers can re-enter the market
If you’re planning proposals this fiscal year, especially in federal contracting certifications or using women owned small business certification, now is the time to tighten up your NMR compliance processes.
Need more tactical insights? Check out our related post onCongress Is Making Moves: Here’s What 8 Key Bills Could Mean for Small GovCon Players to make sure your entire small business strategy stays audit-proof.
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