TAA Designated Countries List 2022

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TAA non-compliance is one of the most common reasons for GSA contract cancellation or at least putting it on hold. Every product you sell to the federal agencies must be manufactured or substantially transformed in either the U.S. or in one of the designated countries. Since the list of designated countries changes over time, it is vital to know what  TAA compliant countries are in 2022, in order to act accordingly and to remain compliant. 

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What is the TAA (Trade Agreement Act)

The Trade Agreements Act or shortly TAA is a Federal Law that governs trade agreements between the United States and other countries. One of the most important features of the Act is that it instructs the GSA and federal agencies to only procure products manufactured or substantially transformed in the U.S. or in one of the TAA designated countries. The GSA country of origin must therefore be included in the TAA compliant country list; otherwise the product is considered non TAA compliant and the GSA cannot not continue purchasing under such a GSA contract. 

The TAA compliant countries list can be found in the FAR-Clause-52.225-5, which is regularly updated.

What is TAA compliance

What is TAA compliant definition

TAA compliance is nothing more than compliance to the Trade Agreement Act of 1974. However, since TAA compliant countries often change, the exact definition of “TAA compliant” may also change.

So, the best definition of TAA compliance is as follows: your product is TAA compliant if it is either fully manufactured within the territory of one of the GSA compliant countries, specifically those that are included in the list of TAA compliant countries, or if it is substantially transformed in such countries.

On the contrary, if the product or any part of it was either manufactured in one of non TAA compliant countries and has not gone through substantial transformation in a compliant jurisdiction (see below), the product is deemed non TAA compliant.

What is “substantial transformation” mentioned above? The substantial transformation process means that a product must be modified or transformed significantly, and that modification must add something new to the product or alter its characteristics in a substantial way. If the product was substantially transformed in one of TAA approved countries, it is considered as manufactured in that country, and hence becomes TAA compliant.

Who makes the determination of TAA compliance?

Technically, you do. You see, the U.S. Customs and Border Protection states that “the responsibility for making a determination of substantial transformation rests solely with the contractor”. Which means that it is your responsibility to check and maintain TAA compliance of your products. 

However, a GSA contracting officer or even your competitor may spot some TAA compliance issue and submit a protest to the General Services Administration. This may result in suspension or even cancellation of your GSA contract entirely!

Are your products on GSA Schedule TAA compliant?

Unfortunately, there is not a quick and sure way to check if a product on the GSA Schedule is TAA compliant or not. You have to go the harder way: contact the manufacturer and request  compliance documents. Sometimes, you may need to go deeper and ask for compliance documents for parts of the product that are assembled into the final product. Overall, it is your responsibility to request all the compliance documents, check supply chains for compliance, and make sure that third-part components used in the product are from GSA approved countries.

How to keep your GSA Schedule contracts TAA compliant?

Maintaining TAA compliance of your GSA contract means keeping all and every aspect of your product TAA compliant. And this means a lot of work of learning the country of origin for every single product in your price list. Moreover, you should maintain your TAA compliance constantly, as this isn’t a one-time affair.

When you have just so many products sold to the government, you can maintain TAA compliance with your own capabilities. But what if you have hundreds or even thousands of products? What if these products have multiple versions and models? Manual tracking of whether a product originates from a TAA compliant country would then consume all of your time! And you have business to conduct,  aside from monitoring changes in the TAA countries list.

In this case, we recommend hiring a GSA contracting specialist, such as Price Reporter. Experienced professionals have their own ways to quickly check TAA compliance of a product. They can discover the true country of origin and see if it is one of the Trade Act compliant countries or not.

If you want to a get free consultation, please contact Price Reporter.

TAA Compliance by country, 2022

Below is the most current TAA compliant list of countries that your product may originate from (or be substantially transformed in) to be considered TAA compliant in 2022.

Current list of TAA compliant countries include

The Trade Agreement Act countries that are considered TAA compliant:

United StatesBangladeshMexicoJapanEthiopiaDR CongoGermanyUnited KingdomTanzaniaFranceItalyColombiaSouth KoreaSpainUgandaAfghanistanPolandUkraineCanadaMoroccoAngolaPeruYemenMozambiqueNepalMadagascarNigerAustraliaTaiwanBurkina FasoMaliMalawiZambiaRomaniaChileGuatemalaChadSomaliaNetherlandsSenegalCambodiaGuineaRwandaBeninBurundiBelgiumHaitiDominican RepublicSouth SudanSwedenCzech RepublicHondurasGreecePortugalHungaryIsraelAustriaTogoSwitzerlandLaosHong KongNicaraguaBulgariaEl SalvadorSingaporeDenmarkSlovakiaCentral African RepublicFinlandNorwayLiberiaNew ZealandCosta RicaIrelandMauritaniaOmanPanamaCroatiaEritreaMoldovaJamaicaArmeniaLithuaniaGambiaLesothoSloveniaGuinea-BissauLatviaEquatorial GuineaTrinidad and TobagoBahrainTimor-LesteEstoniaCyprusDjiboutiComorosGuyanaBhutanLuxembourgMontenegroMaltaMaldivesBahamasBelizeIcelandVanuatuBarbadosSao Tome and PrincipeSamoaCuracaoSaint LuciaKiribatiGrenadaArubaSaint Vincent and the GrenadinesAntigua and BarbudaDominicaSaint Kitts and NevisSint MaartenLiechtensteinBritish Virgin IslandsTuvaluMontserrat

Non-TAA compliant countries list below

Below are the Trade Agreement Act countries that are considered TAA non-compliant countries in 2022:

Sri Lanka

Is it really important to check for TAA compliance in 2022?

Yes, this matter is of utter importance for your GSA contract. The GSA Trade Agreement Act applies to all Schedules, and this means that failure to maintain TAA compliance of just a single product under one Schedule can automatically put all your Schedules under the contract on hold.

It is vital to check the TAA country list from time to time and make sure there are no significant changes due to politics, economical reasons, and such. Also, you should make sure that every component of your product is manufactured in Trade Agreement Act countries or at least was substantially transformed in one of them.

Moreover, there is growing attention to TAA compliance from contracting officers today. And while TAA compliance is still largely a self-certification procedure, it is your responsibility to check for TAA compliance and fix any compliance issues you find as soon as possible. At Price Reporter, we often receive complaints from our clients that some of their competitors abuse the TAA compliance mechanism, and try to use this as a reason to submit a protest and hence clear the federal market from unwanted competition, that wasn’t accurate and diligent enough to maintain TAA compliance for their products.

Don’t be one of those unlucky GSA contractors who lost their Schedule because of inattention to the country of origin of their products. Manage your TAA compliance!

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