Separate from the Buy American Act, which pertains to federal procurements, Buy America statutes impose domestic source restrictions on federal grants. Buy America restrictions apply to all American Recovery and Reinvestment Act funds, as well as Department of Transportation grants administered by the Federal Aviation Administra- tion (FAA), the Federal Highway Administration (FHWA), the Federal Transit Administration (FTA) and the Federal Railroad Administration (FRA). Although each Buy America provision generally requires the use of iron, steel and manufactured goods that are “produced in” the United States, the interpretation and application of this requirement differs depending on the statute at issue and each agency’s implementing regulations. For example, the FTA Buy America statute includes a waiver for certain rolling stock items, and FHWA only applies its Buy America restrictions to manufactured products consisting of at least 90 percent steel or iron. The FRA is currently in the process of developing and implementing regulations that will govern the FRA Buy America statute, which was just enacted in 2008. If history is any guide, FRA’s implementing regulations will only add more complexity to the already confusing world of Buy America restrictions.