How a U.S. manufacturer evidences the export nexus, converts a staffing plan into job-years that size the loan, and satisfies EXIM's reasonable assurance of repayment standard. Independent, sourced, and written to be read by a credit officer.
The Make More in America Initiative (MMIA) opens the Export-Import Bank of the United States' existing medium- and long-term loans, loan guarantees and insurance to export-oriented domestic manufacturing projects built on U.S. soil. Wert-Berater, Inc. prepares the independent feasibility study, market study, business plan and fully linked financial model that a U.S. manufacturer submits in support of an MMIA application. The eligibility questions are unusual: instead of the U.S. content calculation that governs a foreign-buyer transaction, MMIA turns on an export nexus and a jobs-based sizing test, and it layers EXIM's congressional reasonable-assurance-of-repayment standard on top. Each of those is an evidentiary question, and each is answered in the study rather than asserted in a cover letter. This page walks through the initiative and then works each test in turn, including a clearly labelled illustrative example of the job-year arithmetic that sizes the loan.
The initiative addresses a structural gap. A U.S. manufacturer that intends to compete for global sales has to build domestic capacity first, and the financing for that capacity has historically been harder to assemble than the financing available to the foreign buyers who purchase the finished goods. MMIA closes that gap by pointing EXIM's established medium- and long-term instruments inward, at the domestic plant, rather than solely at the overseas purchaser. The instruments themselves are not new; what MMIA changes is the borrower and the eligibility logic that qualifies the borrower.
Because the initiative is open to all sectors, the first thing a study establishes is which lane a project sits in. That determines the applicable export-nexus threshold and signals whether the transaction carries a financing priority. Transformational export areas — a Congressionally defined set that includes semiconductors, biotech and biomedical products, renewable energy and energy storage — are treated favorably, as are small businesses and environmentally beneficial projects. For the broader relationship between MMIA and EXIM's other transaction families, the EXIM feasibility study hub is the place to start.
The two thresholds are not interchangeable, and matching a project to the correct one is the opening move of the analysis. A small business, a transformational-export-area project, or a climate-related transaction is measured against the lower 15 percent bar. A project that falls outside those categories is measured against the 25 percent bar. The study documents the classification before it documents the percentage, because the classification decides which percentage has to be reached.
Two features of the nexus rule are easy to miss and both matter. First, export suppliers can qualify, not only the manufacturer whose name is on the final export contract; a firm that sells components or inputs into an export supply chain can meet the standard if the nexus is satisfied. Second, and more important, the rule reads "exported or expected to be exported." That phrase is the analytical heart of an MMIA study.
"Expected to be exported" is a projection that must be evidenced. A forward-looking export percentage is acceptable to EXIM, but only as an evidenced projection — not as an assertion. The study supports it with letters of intent, distributor and offtake agreements, purchase orders, and a destination-market demand analysis that shows the projected export volume can actually be absorbed at the assumed price. An unsupported export percentage is the single most common reason a thin MMIA application stalls. If the export nexus is a number in a spreadsheet with nothing behind it, treat the application as not yet ready.
This is where a staffing plan stops being administrative detail and becomes the instrument that sizes the loan. EXIM counts jobs in two buckets: the construction jobs supported while the plant is built, and the operating jobs supported over the life of the financing. Both are converted into job-years, where one job held for one year is one job-year, and the total is multiplied by the per-job-year allowance of $229,502 to derive the indicative financing capacity. A robust, defensible staffing model is therefore worth as much to the sizing outcome as the market study is to the nexus outcome.
The figures below are illustrative only. They are invented to demonstrate the arithmetic and do not describe any real project, any real applicant, or any commitment by EXIM. Every real engagement builds these numbers from the sponsor's own staffing plan, the construction labor schedule, and occupational wage data, and the resulting capacity is EXIM's determination, not ours.
| Job category (illustrative) | Jobs | Years counted | Job-years |
|---|---|---|---|
| Construction workforce (build-out period) | 60 jobs | 1.5 years | 90 job-years |
| Permanent operating staff (over financing term) | 40 jobs | 5 years | 200 job-years |
| Total job-years | — | — | 290 job-years |
At the published allowance, 290 job-years × $229,502 per job-year yields an indicative financing capacity of roughly $66.6 million (290 × $229,502 = $66,555,580). The point of the exercise is not the headline figure; it is the discipline behind it. Each job in the table has to be a real position with a defensible wage, a start date tied to the construction and commissioning schedule, and a duration that does not outrun the financing term. Inflated headcount, phantom shifts, or operating jobs counted for longer than the loan tenor all collapse under review. Because this test replaces U.S. content for domestic deals, the staffing model carries weight it would never carry in a foreign-buyer transaction — see the EXIM feasibility study requirements page for how the employment schedule fits the wider application.
EXIM operates under a congressional reasonable-assurance-of-repayment standard, and the initiative does not waive it. For a corporate MMIA borrower that is not using a limited-recourse structure, that standard resolves into three practical tests the study is built to answer:
Not every MMIA project fits the corporate route. Where the transaction depends on the project's own future cash flow rather than an established borrower's balance sheet, it is assessed as limited-recourse project finance instead, under a different and deeper set of criteria. If your deal looks more like a standalone project than a corporate expansion, read the EXIM project finance feasibility study page and the explanation of Attachment F (Form EIB 95-10f), which is the domestic and foreign project finance attachment — not, despite frequent third-party confusion, a feasibility-study form.
The table below maps each MMIA eligibility test to the evidence a sponsor must produce and the section of a Wert-Berater study that produces or reconciles to it. Items marked sponsor are the sponsor's to supply; we identify them, reconcile to them, and flag them when they are missing.
| MMIA test | Evidence the sponsor must produce | Section of our study that produces it |
|---|---|---|
| Sector classification (15% vs 25% lane; priority category) | Small-business status, transformational-export-area or climate categorization, product description | Business plan and market study — project classification and applicable-threshold determination |
| Export nexus — 15% or 25% exported or expected to be exported | Letters of intent, distributor and offtake agreements, purchase orders, destination-market absorption evidence (sponsor contracts) | Export-market analysis and the documented, evidenced nexus calculation |
| Jobs — construction jobs supported | Construction labor schedule tied to the build-out timeline, contractor headcount by trade | Employment schedule by phase — construction job-year computation |
| Jobs — operating jobs supported over the financing term | Staffing plan by role, prevailing and occupational wages, shift structure | Operating staffing model and job-year rollup at $229,502 per job-year |
| Reasonable assurance — three-year revenue history in the same line of business | Audited or reviewed statements and tax returns for three years (sponsor) | Historical financial analysis and same-line-of-business confirmation |
| Reasonable assurance — proven debt service capacity | Existing debt schedule, historical cash flow, coverage record | Debt-service analysis and downside sensitivity, project and global basis |
| Reasonable assurance — loan proportionate to tangible net worth (guide: ≤40%) | Current balance sheet with intangibles identified (sponsor) | Tangible-net-worth computation and requested-amount ratio |
| Standard due diligence and additionality | Market context and evidence of the financing gap MMIA fills | Economic impact and additionality commentary; market-displacement review |
Every other test in an MMIA application is either a matter of record — three years of statements, a balance sheet, a headcount schedule — or an arithmetic operation on figures the sponsor already holds. The export nexus is different. When it rests on output expected to be exported, it is a claim about the future, and it is the one figure in the file a reviewer cannot verify from the sponsor's own back-office documents. That is why it draws the closest scrutiny, and why it is the piece of the analysis that most often decides whether an application proceeds.
Answering it well means treating the export percentage as a conclusion, not a premise. The market study identifies the destination markets, quantifies demand for the plant's specific output rather than for its industry in general, tests the assumed pricing against observable market pricing, and traces the route to market through named distributors or offtakers. The export volume that survives that analysis is the volume the nexus rests on. When the number is built this way, it withstands the adversarial reading EXIM's own market consultant will give it; when it is asserted, it does not. For a manufacturer building the plant behind the projection, the discipline of the manufacturing plant feasibility study and the capacity ramp it models is what makes the export figure credible in the first place.
Wert-Berater has prepared more than 4,000 feasibility studies since 1998, covering $40.2 billion in evaluated project value across all 50 states. Relevant adjacent work includes manufacturing facility studies in Bulgaria, Finland, the Czech Republic, Germany and Saudi Arabia; oil and gas refinery studies in Qatar and Dubai, including a 50,000-barrel-per-day refinery and a used-lube-oil re-refinery; a 150,000-square-foot indoor food production facility in Qatar; and an extensive record of SBA 504/7(a) studies prepared to SOP 50 10 8 and USDA Business & Industry studies prepared to RD Instruction 5001. Those federal programs apply the same discipline MMIA applies — documented demand, benchmarked capital cost, stress-tested coverage, an independent author.
We want to be exact, because export finance rewards precision. Wert-Berater has not to date completed an engagement financed by EXIM, and we make no claim that any agency has approved, accepted or reviewed our work. Our studies are prepared to address EXIM's published requirements using an EXIM-aligned methodology; whether a given MMIA application succeeds is EXIM's determination, not ours. Every study is delivered through a secure client portal, and standard delivery is 10–15 business days from complete project data, with export-nexus verification across multiple destination markets extending that where the analysis warrants. Scope, timeline and a fixed fee are confirmed in writing before work begins, and no fee is contingent on the finding.
It is a repurposing of EXIM's established instruments toward the domestic plant, with an eligibility logic — export nexus plus jobs-based sizing — built for a domestic borrower rather than a foreign buyer. Start at the EXIM feasibility study hub for how it sits alongside EXIM's other transaction families.
The study classifies the project first, because the classification decides which threshold applies, then evidences the percentage against that threshold with contracts, letters of intent and a destination-market demand analysis.
The staffing plan and construction labor schedule therefore drive the indicative financing capacity, which is why the study builds both from wage data and the construction timeline rather than assuming them.
The Exporter's Certificate and content calculation apply to foreign-buyer medium- and long-term financing, not to the domestic MMIA sizing calculation.
A first-time exporter must support the projected export percentage with letters of intent, distributor agreements, purchase orders and a destination-market demand analysis. An unsupported projection is the most common reason a thin application fails.
If your deal is structured as limited-recourse project finance, the three-year corporate test gives way to the project finance criteria described on the project finance feasibility study page.
EXIM facts summarized from EXIM published guidance: Make More in America Initiative, Our Approach to Project Finance, Content Policy (Medium- and Long-Term), and the Application for Long-Term Loan or Guarantee (EIB 95-10) and attachments. EXIM requirements change; confirm current guidance with EXIM or your lender before relying on any summary, including this one.
Tell us the product, the plant, the destination markets you expect to serve, and the corporate or project structure you are contemplating. We will tell you which nexus threshold applies, what the job-year math implies for sizing, what evidence you still need for the export projection, and what the study will cost — before you commit to anything.
Qualify an MMIA project. Scope, timeline and fee confirmed in writing before work begins. Independent findings, never contingent on the outcome.
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