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Reliance on Supplier's Country of Origin Certification Reasonable

Client Alert | 1 min read | 09.04.14

On August 29, 2014, the D.C. Circuit affirmed the grant of summary judgment for the contractor in a qui tam FCA case alleging Govplace had violated the Trade Agreements Act (TAA) by unreasonably relying on the distributor's country of origin certification and selling IT hardware that allegedly failed to comply with the TAA. The court concluded not only that Govplace could reasonably rely on the distributor's certification (a practice it had disclosed to GSA during Contractor Administrator Visits), but also that, because the hardware was generally manufactured in both TAA-designated countries and in non-designated countries, neither an email from the manufacturer's employee nor a competitor's price list suggesting conflicting country of origin information undermined Govplace's continued reliance on the distributor's certification.

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Client Alert | 3 min read | 11.12.25

EPA Proposes Important Revisions to its PFAS Reporting Regulations

On November 10, 2025, the U.S. Environmental Protection Agency (EPA) released proposed regulations that, if adopted, would substantially alter the reporting obligations of companies that manufacture or import products containing per- or polyfluoroalkyl substances (PFAS). The proposed regulations would significantly reduce reporting burdens by exempting numerous products that currently trigger reporting requirements under EPA’s PFAS reporting regulations.  The proposed regulations would also delay the current deadline for reporting....