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  3. |A Bold New World? GSA Proposes to Swap Its Price Reduction Clause for Monthly Reporting of All Sales Under Schedule and Other Government-Wide GSA Contracts

A Bold New World? GSA Proposes to Swap Its Price Reduction Clause for Monthly Reporting of All Sales Under Schedule and Other Government-Wide GSA Contracts

Client Alert | 1 min read | 03.06.15

On March 4, 2015, GSA proposed to change dramatically the way it seeks to obtain the lowest and best price for items purchased off Federal Supply Schedule and other Government-wide GSA contracts by largely abandoning the Price Reduction Clause (and the consequent price monitoring of sales to "basis of award" customers) in favor of imposing a requirement that holders of such contracts report, on a monthly basis, specific information on all sales transactions (including unit prices) to authorized users. While the Price Reduction Clause has caused contractors significant compliance difficulties over the years, this proposal, which will be considered at a April 17 public meeting with written comments due May 4, is intended to provide government customers a powerful database tool by which to obtain the best deal from contractors based upon their actual price history and the ability to compare those unit prices with the actual prices being offered by competitors.

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Client Alert | 4 min read | 06.24.25

CBP Issues First Comprehensive Guide to Modifying a Withhold Release Order (WRO)

On June 2, 2025, U.S. Customs and Border Protection (“CBP”) issued its first ever Withhold Release Order (“WRO”) and Finding Modifications Guide (“Guide” or “the Guide”). The Guide serves as a roadmap for importers facing a possible WRO or Finding due to allegations of forced labor in the supply chain of their goods imported into the U.S. It provides guidance on information to be included in a modification petition, identifies possible cases in which CBP might request additional information, and provides resources for importers facing a WRO or Finding....