For any contractor interested in selling its’ products on a GSA Schedule, it is pertinent that you become familiar with, as well as compliant with the Trade Agreement Act (TAA). The TAA outlines where products the government purchases can be manufactured. As GSA Schedule solicitations contain TAA provisions, when applying for a GSA Schedule, your product’s Country of Origin (COO) must be included in the proposal, compliant with the TAA, and accurate.
Determining a product’s COO can be complicated. While products that are wholly made in one country are simple to designate a COO for, most products contain numerous parts made in various countries. In these cases, the product’s COO is classified by Federal Acquisition Regulation (FAR) 52.225-5 as “the country in which the product has been substantially transformed into a new and different article of commerce with a name, character, or use distinct from that of the articles from which it was transformed”. Once a product’s COO has been determined, verify it is TAA compliant.
Federal Acquisition Regulation (FAR) 52.225-5 defines TAA compliant countries as:
- “A World Trade Organization Government Procurement Agreement country (Aruba, Austria, Belgium, Bulgaria, Canada, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hong Kong, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea (Republic of), Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Netherlands, Norway, Poland, Portugal, Romania, Singapore, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Taiwan (known in the World Trade Organization as “the Separate Customs Territory of Taiwan, Penghu, Kinmen and Matsu (Chinese Taipei))”, or United Kingdom)
- A Free Trade Agreement country (Australia, Bahrain, Canada, Chile, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Mexico, Morocco, Nicaragua, Oman, Peru, or Singapore)
- A least developed country (Afghanistan, Angola, Bangladesh, Benin, Bhutan, Burkina Faso, Burundi, Cambodia, Central African Republic, Chad, Comoros, Democratic Republic of Congo, Djibouti, East Timor, Equatorial Guinea, Eritrea, Ethiopia, Gambia, Guinea, Guinea-Bissau, Haiti, Kiribati, Laos, Lesotho, Liberia, Madagascar, Malawi, Maldives, Mali, Mauritania, Mozambique, Nepal, Niger, Rwanda, Samoa, Sao Tome and Principe, Senegal, Sierra Leone, Solomon Islands, Somalia, Tanzania, Togo, Tuvalu, Uganda, Vanuatu, Yemen, or Zambia)
- A Caribbean Basin country (Antigua and Barbuda, Aruba, Bahamas, Barbados, Belize, British Virgin Islands, Dominica, Grenada, Guyana, Haiti, Jamaica, Montserrat, Netherlands Antilles, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, or Trinidad and Tobago)”
Should you have questions regarding TAA compliance or need assistance adding your TAA compliant products to a GSA Schedule, Please contact Winvale for assistance.
About Brian Dunn
A founding partner of Winvale, Brian Dunn manages and supervises all professional services for company clients, among them business intelligence and market assessment, schedule maintenance, OIG audits, training, sales strategy and business development. Under Brian’s direction, Winvale has successfully negotiated and managed hundreds of GSA Schedule contracts for companies of many sizes and representing many industries. Brian’s expertise with GSA’s Multiple Award Schedule is the driver behind Winvale’s nearly perfect contract approval rate, and continues to power customer success.