DPAS rated orders: checklist and acceptance deadlines

A DO or DX rated order gives your supplier 15 or 10 working days to accept it in writing or electronically, or reject it with reasons. An order missing one of the four required elements isn't a valid rated order, and a supplier that misses the acceptance window is in breach of the rule.

What is a DPAS rated order?

A DPAS rated order is a purchase order or contract that carries a priority rating under the Defense Priorities and Allocations System. The rating combines a DO or DX symbol with a program identification symbol, such as DO-A1 for a defense aircraft program, and tells suppliers that this order comes ahead of unrated work.

The rating symbol and program identification symbol are defined in 15 CFR 700.11(c). On a government contract, the solicitation carries FAR 52.211-14, where the contracting officer checks DO or DX, and the award carries FAR 52.211-15. A sub-tier supplier sees the rating on its customer's purchase order. Your purchase orders for what you need to fill that contract must carry the rating too. 15 CFR 700.15.

What must a valid rated order contain?

A valid rated order carries the priority rating and program identification symbol, a required delivery date or dates, the signature of someone authorized to sign rated orders, and the required certification statement. 15 CFR 700.12(a). "Immediately" or "as soon as possible" isn't a delivery date, so an order that only says that isn't valid yet.

What a valid rated order contains

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A checklist table of the elements a DPAS rated order must contain: the priority rating and program identification symbol, a required delivery date or dates, an authorized signature, and the certification statement, plus the extra time-limit statement required only on emergency preparedness orders. Each row states the requirement in plain language and pins it to its 15 CFR 700.12 source.

Element	Requirement	Source
Priority rating and program identification symbol	The DO or DX symbol paired with the program symbol for the approved program, for example DO-A1.	15 CFR 700.12(a)(1)
Required delivery date or dates	A specific date. 'Immediately' or 'as soon as possible' does not count as a delivery date.	15 CFR 700.12(a)(2)
Authorized signature	The written signature on a manually placed order, or the digital signature or name on an electronic order, of someone authorized to sign rated orders.	15 CFR 700.12(a)(3)
Certification statement	The order states it is a rated order certified for national defense use and that the recipient must follow the DPAS regulation.	15 CFR 700.12(a)(4)
Time-limit statement (emergency preparedness orders only)	An additional statement setting a time limit for acceptance or rejection, which can be as short as 6 hours after receipt for a hazard that has occurred, or 12 hours after receipt for an imminent one.	15 CFR 700.12(b); 700.13(d)(2)

Check the rating and program symbol against Schedule I, check for an actual date, check who signed it, and check that the certification statement names 15 CFR part 700. A verbal promise that an order is rated, with none of this printed on the document, isn't a rated order. A rating doesn't shorten a supplier's quoted lead time, but it moves the order ahead of unrated work when that's what it takes to meet the date.

What is the difference between a DO and a DX rated order?

DX is the higher of the two priority levels. Every DX rated order outranks every DO rated order and every unrated order; every DO rated order outranks every unrated order. 15 CFR 700.11(a). When two orders compete for capacity at the same level, fill the one with the earlier delivery date; if both are due the same day, whichever was received first wins. 15 CFR 700.14(c)(1).

A DO rated order must get production preference over unrated work if that's what it takes to hit its delivery date, even if it means pulling parts already in process or ready to ship against an unrated order. A DX rated order gets that same preference over DO and unrated orders. 15 CFR 700.14(b). If you can't buy an input in time to meet a rated order's date, fill it from your own inventory instead. 15 CFR 700.14(d).

How fast must a supplier accept or reject a rated order?

A DO rated order must be accepted or rejected in writing or electronically within 15 working days of receipt; a DX rated order within 10 working days. 15 CFR 700.13(d)(1). A working day is any day the recipient is open for business. 15 CFR 700.8. A rejection has to give the reasons.

An emergency preparedness order sets its own time limit, which can be as short as 6 hours after receipt when the order responds to a hazard that has occurred, or 12 hours after receipt when it prepares for an imminent one. 15 CFR 700.13(d)(2). Once a supplier accepts a rated order and later finds it can't meet the date, it has to tell you immediately, with the reasons and a new date, and confirm a verbal notice in writing or electronically within one working day. 15 CFR 700.13(d)(3). Check that new date against your need date the same way you would on any other order, covered in promise date vs need date, and see purchase order acknowledgement for what the acceptance should also say about quantity and price.

When must a supplier reject a rated order, and when may it choose to?

A supplier must reject a rated order it can't meet, or one that would bump a date already promised on another equal or higher-rated order, offering the earliest date instead. 15 CFR 700.13(b). Otherwise a supplier must accept every rated order, on the same prices and terms as comparable unrated orders. 15 CFR 700.13(a). A clash with unrated work already accepted is no reason to reject. 15 CFR 700.13(b)(1).

A supplier can turn down a rated order, without treating that customer worse than others, when:

• The buyer won't meet the supplier's regularly established terms of sale or payment.
• The order asks for an item the supplier doesn't sell or a service it doesn't perform.
• The item exists only for the supplier's own use and hasn't been sold to anyone else in the last two years; if some was sold in that time, the supplier must accept rated orders up to that quantity.
• The buyer itself makes the item or performs the service, unless the buyer is the US Government.
• Accepting would break another Commerce regulation, official action or order issued under the Defense Production Act or the Selective Service Act.

Do you have to flow a rated order down to your own suppliers?

Yes. If filling a rated order means buying materials or parts from your own suppliers, you have to place a rated order with them too, carrying the same rating and the same four required elements. 15 CFR 700.15(a)-(b). The rating passes from contractor to subcontractor to supplier all the way down the chain.

Leave the rating off your own purchase order and your supplier has no reason to treat it as anything but routine work, which also means it won't owe you the 15- or 10-working-day acceptance either. Orders under $175,000 don't have to carry the rating if delivery comes in time without it. 15 CFR 700.17(f).

Rated order timeline, from receipt to special priorities assistance

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A five-stage left-to-right timeline for a DPAS rated order: receipt of the order, the acceptance-or-rejection deadline (15 working days for a DO order, 10 for a DX order), flowing the rating down to sub-tier suppliers, performing against the schedule with preferential scheduling over unrated work, and filing for special priorities assistance if problems remain. Each stage lists what happens and its governing rule.

1. 1

   Receipt

   What happens

   The rated order arrives carrying its priority rating, program symbol, delivery date and certification statement.

   Deadline or rule

   Starting point; the acceptance clock begins here

   Source

   15 CFR 700.12

2. 2

   Accept or reject

   What happens

   The supplier accepts or rejects the order in writing or electronically, giving reasons for any rejection.

   Deadline or rule

   15 working days after receipt for a DO order; 10 working days for a DX order

   Source

   15 CFR 700.13(d)(1)

3. 3

   Flow the rating down

   What happens

   If filling the order needs items from the supplier's own suppliers, it places a rated order with them carrying the same elements and rating, unless that order is under $175,000 and delivery comes in time without it.

   Deadline or rule

   No fixed deadline; done as those purchase orders are placed

   Source

   15 CFR 700.15; 700.17(f)

4. 4

   Perform against the schedule

   What happens

   The rated order gets production preference over unrated work, and a DX order over a DO order, even if it means diverting items already in process or ready to ship.

   Deadline or rule

   Ongoing through delivery

   Source

   15 CFR 700.14(b)

5. 5

   Special priorities assistance if problems remain

   What happens

   After a reasonable effort to resolve the problem, the customer or supplier files Form BIS-999 for government help.

   Deadline or rule

   No fixed deadline, but the request should be timely

   Source

   15 CFR 700.50(c), 700.53

What happens when a rated order still isn't performing?

Special priorities assistance is the government's channel for a rated order that's stuck, usually provided when a supplier won't perform, you can't find a source, or otherwise can't hit a date. 15 CFR 700.52(a). File Form BIS-999 only after a reasonable effort to fix it yourself, showing urgent need and that effort, so keep a dated record of every contact with the supplier. 15 CFR 700.50(c). 15 CFR 700.53.

Where you file depends on who placed the rated order. If a Delegate Agency such as the Department of Defense placed it, take the request to that agency's contract administration officer first; it can escalate to Commerce if it can't resolve the problem itself. If another authorized person placed the order, go straight to the Department of Commerce. 15 CFR 700.50(a). Commerce or the Delegate Agency may refuse a request aimed at getting delivery earlier than the rated order actually requires. 15 CFR 700.54(b). See expediting for the recovery options once you're chasing that date.

What happens if you don't follow the rules?

Willfully ignoring a rated order, or refusing to flow the rating down, is a federal crime. The Defense Production Act sets a fine of up to $10,000, up to a year in prison, or both. 50 U.S.C. 4513. The general federal fine statute can raise that ceiling. 18 U.S.C. 3571.

The priorities authority behind rated orders, and this penalty, sit in Title I of the Defense Production Act, which expires on December 11, 2026 unless Congress extends it. 50 U.S.C. 4564(a). The criminal penalty applies to willful violations. The government can also ask a court for an injunction to stop a violation or enforce compliance, willful or not. 15 CFR 700.74(b). Check your contract and counsel.

Where do rated orders usually break down?

The rating gets buried in an email instead of printed on the order itself, so nobody downstream sees it. A supplier re-promises a new date by phone and never confirms it in writing within one working day. The rating never makes it onto the purchase order placed with a sub-tier supplier, so the obligation dies at the first tier.

On your side as the buyer, put a name against every rated PO line before it goes out, so the rating, the date and the certification statement sit on the document your supplier actually sees. Track the 15- or 10-working-day acceptance clock the way you'd track any other confirmed date on your purchase order tracking, and check that each supplier's written acceptance arrives inside the window and confirms the delivery date on your rated PO before you count on it.

On the supplier side, train whoever opens purchase orders to recognize a rating on sight and route it to whoever can accept or reject it in writing inside the window, and make flowing the rating down to your own suppliers a normal, every-time step in your own purchasing process.

A readiness signal can't tell a rated order from an unrated one, so it opens a task for any order that still has no confirmed date, and Cartograph hands it to your team or Scout Agent. Scout Agent emails and calls the supplier for a written acceptance with dates, within the permissions your team sets.

Questions teams ask

Can a supplier charge more for a rated order?

No. A supplier can't charge higher prices or set different terms than it charges for comparable unrated orders. 15 CFR 700.13(a)(2).

Can I accept a rated order for a date I can't actually hit?

No. Offer the earliest date you can hit instead, and let the customer decide whether to take it or look elsewhere. 15 CFR 700.13(b)(1).

Does the rating apply to a purchase order I place with a distributor or a raw material supplier?

Usually, yes. A purchase you need to fill a rated order carries the rating whoever the supplier is, with two exceptions. You don't have to rate an order under $175,000, half the simplified acquisition threshold, if delivery comes in time without it. 15 CFR 700.17(f). Some raw materials, such as copper raw materials and scrap, can't be rated without Commerce authorization. 15 CFR 700.18(b).

What if a rated order and an unrated order need the same production slot?

The rated order wins. 15 CFR 700.14(b) requires you to give the rated order preference, even by diverting an item already in process or ready to ship against the unrated order, if that's what it takes to meet the rated date. Tell the unrated customer as soon as you know its date is moving.

If your team is tracking rated-order deadlines from memory, talk to our team about how Cartograph opens a task for every PO line that still has no confirmed date.

This article is general information, not legal or tax advice. Check how the rules apply to your business with your legal or tax advisor.

Sources (18)

1. 15 CFR 700.8, Definitions ('working day')
2. 15 CFR 700.11, Priority ratings
3. 15 CFR 700.12, Elements of a rated order
4. 15 CFR 700.13, Acceptance and rejection of rated orders
5. 15 CFR 700.14, Preferential scheduling
6. 15 CFR 700.15, Extension of priority ratings
7. 15 CFR 700.17 Use of rated orders
8. 15 CFR 700.18 Limitations on placing rated orders
9. 15 CFR 700.50, Special priorities assistance, general provisions
10. 15 CFR 700.52, Examples of assistance
11. 15 CFR 700.53, Criteria for assistance
12. 15 CFR 700.54, Instances where assistance will not be provided
13. 15 CFR 700.74, Violations
14. 50 U.S.C. 4513, Penalties (via uscode.house.gov)
15. 50 U.S.C. 4564, Termination of authority (via uscode.house.gov)
16. 18 U.S.C. 3571, Sentence of fine (via uscode.house.gov)
17. FAR 52.211-14, Notice of Priority Rating for National Defense, Emergency Preparedness, and Energy Program Use
18. FAR 52.211-15, Defense Priority and Allocation Requirements