First article testing on a DLA contract means you build and prove a sample, or have the government test it, before the rest of the order is approved. It adds cost, time and risk to your quote. The FAR puts most of that risk on you until approval comes through, so price first article as its own job, read the FAT clause before you quote, and ask for a waiver if you've already delivered the same or a similar item and the government accepted it.

What first article testing is on a DLA contract

The FAR describes first article testing and approval as a way to make sure the contractor can furnish a product that conforms to all contract requirements for acceptance (FAR 9.302). "Approval" means the contracting officer's written notice accepting the test results.

FAR 9.303 lists when it may be appropriate, including when:

• the contractor hasn't previously furnished the product to the government;
• the contractor has furnished it before, but processes or specifications have changed, production stopped for an extended period, or the product developed a problem in service;
• the product is described by a performance specification; or
• an approved first article is needed as a manufacturing standard.

For a small shop, the first bullet is the one that matters. If you're new to an NSN, expect to see first article more often. And if the NSN is source controlled, first article may not be your biggest hurdle; see Approved Source on DIBBS: What AMSC B, C and D Mean.

First article approval: contractor testing vs. government testing

There are two standard clauses, and they change your pricing (FAR 9.308):

• FAR 52.209-3, First Article Approval, Contractor Testing. You run the tests and submit a first article test report.
• FAR 52.209-4, First Article Approval, Government Testing. The government runs the tests, and the clause carries the delivery schedule for the first article.

Each clause has alternates. Alternate I requires you to make the first article and the production quantity at the same facility. Alternate II lets the contracting officer authorize you to buy material or start production before approval.

Where the risk sits under FAR 52.209-3

This is the part that hurts margins. Under FAR 52.209-3:

• Pre-approval production is at your risk. Before first article approval, buying material or starting production on the rest of the quantity is at your sole risk, unless Alternate II authorization says otherwise (paragraph (g)).
• Retests are on you. If the first article is disapproved, you may have to repeat tests, and the clause says all related costs, including additional tests after a disapproval, are borne by the contractor (paragraph (c)).
• A late or failed report counts as failure to deliver. If you don't deliver the report on time, or the first article is disapproved, you're deemed to have failed to make delivery under the Default clause (paragraph (d)).
• The approved sample can count. Unless the contract says otherwise, an approved first article that wasn't consumed or destroyed in testing may be delivered as part of the contract quantity (paragraph (e)).
• Government delay can earn an adjustment. If the government doesn't act within the specified time, the contracting officer will equitably adjust dates and/or price, but only on your timely written request (paragraph (f)).

How to price first article testing on a DLA quote

There's no formula in the FAR for your number. What follows is a practical way to build it from the clause.

1. Read the fill-in blanks. 52.209-3 has blanks for how many units to test, how many days' notice before testing, and how many days you have to submit the report. Those numbers drive your schedule.
2. Cost the sample separately. Setup, material, machine time and inspection for the first article, as if it were a one-piece order. If testing is destructive, the sample won't count toward the quantity.
3. Cost the testing and report. For contractor testing, include outside lab fees, your inspection time and writing the report. Plan for the notice period, because the government may witness the tests.
4. Carry a retest allowance. Paragraph (c) puts retest costs on you. Decide how much of that risk you'll carry in the price.
5. Price the schedule, not just the part. Production normally waits for approval. FAR 9.305 says the contracting officer should allow enough time in the delivery schedule for materials and for production after approval. Check that the schedule really does.
6. Keep it balanced. If first article is priced as a separate line, FAR 9.306(j) says first article and test prices shouldn't be materially unbalanced against the production quantity. Don't bury production margin in the FAT line or the other way around.

The first article waiver: your best friend on repeat items

Solicitations with first article must tell offerors the requirement may be waived when identical or similar supplies were previously delivered by the offeror and accepted by the government. They must also allow alternative offers, one with testing and one without, if you're eligible (FAR 9.306(c)-(d)). The solicitation also asks for prior contract numbers to document eligibility (9.306(g)). Clause 52.209-3(h) says you may request the waiver.

In practice, keep a clean record of every accepted DLA delivery by NSN and contract number. When the same or a similar item comes back, you'll have what you need for the waiver.

FAR 9.304 also lists cases where testing is normally not required, including products normally sold in the commercial market and products requiring qualification before award (for example, a qualified products list).

A quick first-article checklist before you quote

• Is 52.209-3 or 52.209-4 in the solicitation, and which alternate applies?
• How many units, how many days to report, and where does the report go?
• Is testing destructive?
• Do you qualify for a waiver, and do you have the prior contract numbers?
• Does the production schedule leave room for approval time?
• Have you priced a retest?
• Have you priced the packaging? See MIL-STD-2073 Packaging Codes on a DLA RFQ, Explained.

For the full flow of how to bid on DLA contracts, see How to Bid on DIBBS. For researching the item itself, see How to Research an NSN Before You Bid.

Where FedOpp fits

First article is one of the gates FedOpp reads in plain English before you quote. Your Match Profile records whether you're willing to take first-article work, and FedOpp flags it alongside set-aside, AMSC, packaging and CMMC. The AI Contract Reader turns an uploaded RFQ PDF into a plain-English brief of scope, deadlines and money items. It's assistive research, so always verify against the official solicitation. If you want to screen out first-article RFQs you aren't ready for, try FedOpp free for 7 days.

Frequently asked questions

Can I start production before first article approval?

You can, but under the basic 52.209-3 clause it's at your sole risk. Alternate II lets the contracting officer authorize specific material purchases or production in writing.

Who pays if the first article fails under FAR 52.209-3?

Under 52.209-3(c), the contractor bears the costs of repeated tests after a disapproval. A disapproval can also count as a failure to deliver under the Default clause.

How do I get a first article waiver on a repeat part?

Request a waiver. Solicitations must say the requirement may be waived when you've previously delivered identical or similar supplies that the government accepted, and they ask for the prior contract numbers.

Sources

• FAR Subpart 9.3, First Article Testing and Approval (acquisition.gov, FAC 2026-01)
• FAR 52.209-3, First Article Approval, Contractor Testing (acquisition.gov)

Practical background for small suppliers, not legal advice. The solicitation and your contracting officer control.