A Complete List of TAA Compliant Countries

As a government contractor, especially a GSA Schedule holder, you have to keep track of several regulations to remain compliant. One of the requirements our clients ask about the most is Trade Agreements Act (TAA) compliance. This regulation is neither simple nor clean-cut, and can become quite convoluted for some contractors. However, one non-negotiable is the final products you sell through the GSA Schedule must come from a TAA compliant country. This blog provides an in-depth look at which countries are TAA compliant, which ones are not, and explores the significance of these regulations for government contractors.

Understanding the Trade Agreements Act (TAA)

The Trade Agreements Act of 1979 was established to foster fair and open international trade. The act primarily mandates that the U.S. government may only acquire end products or services from the U.S. or designated countries. These designated countries are considered "TAA compliant" and are proven to have reciprocal trade benefits or are part of international trade pacts with the United States.

So, the final products you sell through your GSA Schedule contract must be:

1. Articles that are wholly the growth, product, or manufacture of the U.S. or a designated country, or
2. Articles that are "substantially transformed" in the U.S. or a designated country into a new and different article of commerce with a name, character, or use distinct from that of the article or articles from which it was transformed.

“Substantially transformed” is defined as a product that has become new and different commerce article in terms of name, character, or use. As I said before though, sometimes TAA compliance can be complicated and you should always consult legal advice if you have questions.

A Comprehensive List of TAA Compliant Countries

The complete list of TAA compliant countries encompasses those that are part of the World Trade Organization Government Procurement Agreement and other free trade agreements. Using the Federal Acquisition Regulation (FAR) 52.225-5, Trade Agreements clause we have put together all the countries that are currently TAA compliant, the newest one being North Macedonia:

If you do not see the country you are looking for on this list, then it is not currently compliant.

Examples of Non-TAA Compliant Countries

Below is a list of the most popular asked-about countries that are currently non-TAA compliant:

It's important to note that this is not an exhaustive list, and you should always check the full TAA list to be sure. 

Navigating TAA Compliance

Ensuring compliance with TAA regulations can be daunting, especially for new contractors. Businesses must verify that their products and services are sourced from TAA compliant countries. Since you can have your GSA Schedule for up to 20 years, that’s a lot of changes to keep up with especially if you change manufacturers for a whole product or even certain parts. You may even introduce new products and services and they have to be deemed TAA compliant as well.

We always counsel our clients to seek legal advice or have it on hand when complicated TAA questions arise, but we also suggest you implement some standard practices such as creating a compliance agreement between your manufacturer, develop TAA compliance training for employees, and ensure you have a team dedicated to managing inventory so there is a host of detailed records.

The TAA compliance status of a country can also change based on geopolitical developments, changes in trade agreements, or adjustments in U.S. trade policy. So, we also suggest you keep a close eye on any developments in newly added countries or countries that are taken off the list in FAR 52.225-5.

Remaining Compliant with Your GSA Schedule

While one of the more difficult regulations, TAA compliance is only one of the many requirements GSA contractors must stay on top of. There’s also sales reporting, modifications, and Contractor Assessment Visits (CAVs) to name a few.

If you want to learn more about managing your GSA contract, check out these blogs below:

• Updating Your GSA Schedule: Top 10 Most Forgotten Updates
• 10 Tips for Successfully Maintaining Your GSA Schedule
• How Do I Report My GSA Schedule Sales?

If you have questions about TAA compliance or other regulations related to your GSA Schedule, Winvale would be happy to help you.