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.
GSA Schedule Contracts are subject to the TAA, meaning all products listed on the GSA Schedule Contract must be manufactured or “substantially transformed” in a “designated country.” The Federal Government wants to know that the products being bought are made domestically or from a country in which we have good diplomatic and economic relations. “Substantially transformed” means that the products for sale have been essentially transformed into a new and different product with a name, character, or use distinctly different from what it was before.
The designated countries are composed of: World Trade Organization Government Procurement Agreement Countries, Free Trade Agreement Countries, Least Developed Countries, and Caribbean Basin Countries. For services, country of origin is determined by the country in which firm providing the services is established, but is still subject to the TAA list of designated countries, which can be found here. Remember to make sure that your product information is accurate in the contract and displayed correctly on GSA Advantage! It’s also a good idea to review the country of origin for the products offered on your GSA contract regularly, as manufacturers sometimes change their manufacturing points.
Foreign acquisition rules are an important compliance issue in the GSA Multiple Award Schedule program. Any GSA awarded contractor needs to keep these in mind, to hold a successful and compliant contract!
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About Haley Lawrie
Haley Lawrie is a consultant in Winvale’s Government Contract Services Department. She is originally from Lynchburg, VA and graduated from James Madison University with a degree in International Affairs and Spanish.
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