GSA Multiple Award Schedule (MAS) contracts have many compliance requirements to ensure that contractors provide products and services that align with federal procurement regulations. One aspect of compliance that many contractors are hesitant about is the Trade Agreements Act (TAA). Under TAA, contractors must agree each "final product" they sell will have been “substantially transformed” in the U.S. or another approved country. GSA contractors often have a lot of questions about “substantial transformation” and what this means. In this blog, we’ll explain the TAA, what “substantial transformation” means, and how Advisory Ruling requests can help you navigate this requirement and remain in compliance.
Some of our most frequently asked questions are about Trade Agreements Act (TAA) Compliance for GSA MAS contracts. TAA Compliance is fairly straightforward, but something contract holders should be regularly monitoring.
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Maintain compliance by keeping up to date with TAA policies! The 2016 Presidential election was filled with a lot of “America first” rhetoric. Within the Trump Administration, that language is continued and there will very likely be an increased importance of American made products purchased through the GSA. With that in mind, reviewing the Trade Agreements Act (TAA) and what it means for GSA spending is important for contractors and buyers alike. The Trade Agreements Act (19 U.S.C. & 2501-2581) of 1979 was enacted to foster fair and open international trade, but more importantly, it implemented the requirement that the U.S. Government may acquire only U.S. – made or designated – end products.