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Wake-up Call: GSA Launches Requirement for Schedule Contractors to Reaffirm TAA Compliance


Concerned with repeated instances of FOIA requests and congressional inquiries exposing contractors offering products not compliant with the Trade Agreements Act on their Federal Supply Schedule contracts, on May 5, 2016, GSA began notifying several contractors that, within five business days, they would need to provide certification that products offered were TAA-compliant or remove them from their offering. The breadth of this initiative continues to unfold, but it serves as a caution for contractors to reevaluate their supply chain and the manner in which they offer products on their FSS contracts under the complex “substantial transformation” rules for establishing country-of-origin under the TAA.

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For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Alan W. H. Gourley
Partner – Washington, D.C., London
Phone: +1 202.624.2561 , +44.20.7413.1342

Adelicia R. Cliffe
Counsel – Washington, D.C.
Phone: +1 202.624.2816

M. Yuan Zhou
Associate – Washington, D.C.
Phone: +1 202.624.2666