Trade Agreements Act (TAA) Compliance for GSA Contractors
The Trade Agreements Act (TAA) prohibits the federal government from purchasing end products from certain countries. GSA Schedule contracts are subject to the TAA, meaning every product you offer on your Schedule must originate from a TAA-designated country. This is not a checkbox — it is an ongoing compliance obligation that requires you to track your supply chain and remove or update any non-compliant items from your pricelist.
What Makes a Country TAA-Designated
TAA-designated countries include the United States, all countries with which the U.S. has a Free Trade Agreement (FTA), many Caribbean Basin Initiative countries, WTO Government Procurement Agreement signatory countries, and Least Developed Countries as defined by the UN. Major economies NOT on the TAA-designated list include China, Russia, India, Malaysia, and Indonesia. Products substantially manufactured in these countries cannot be offered on your GSA Schedule. The list of designated countries is maintained in the FAR and updates periodically as trade agreements change.
Determining Country of Origin
For products, country of origin is typically determined by substantial transformation — which country's production process gave the product its essential character. This is not necessarily where it was assembled or where the final packaging occurred. A product assembled in China from U.S. components is still a Chinese-origin product for TAA purposes. For complex supply chains, obtain country-of-origin certifications from your manufacturer or use a trade compliance attorney to make a determination. GSA may ask for documentation during an audit.
| Country | TAA Eligible? | Basis |
|---|---|---|
| United States | Yes | Domestic |
| Canada, Mexico | Yes | USMCA / FTA |
| EU countries | Yes | WTO GPA |
| China | No | Not designated |
| India | No | Not designated |
| Israel | Yes | FTA |
Services vs. Products Under the TAA
The TAA primarily applies to products/end items. For services, the TAA is generally not directly applicable in the same way — services contracts are not covered by the TAA product restriction. However, services contractors delivering work that involves foreign nationals working offshore may encounter other restrictions (Buy American Act, ITAR, etc.) and should review their specific SIN's requirements. Professional services, IT services, and consulting are generally not subject to country-of-origin requirements the way hardware and physical products are.