36 Comments

1. 

   Ann on April 30, 2014 at 5:43 am

   Is Puerto considered USA? Is it TAA compliant? I don’t see it listed as a TAA complaint Country.

   Thanks

   Reply
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     Julio Cardenas on May 1, 2014 at 10:00 am

     Hello Ann, Puerto Rico will not be in this listing because it is a territory belonging to the United States, therefore making these items TAA compliant. Other U.S. districts and territories and that are also considered TAA compliant are: District of Columbia, American Samoa, Northern Mariana Islands, the aforementioned Puerto Rico, and the United States Virgin Islands. Thanks for your question, I have updated our blog to explain how the TAA applies to US territories.

   • 

     Fillmore Miller on June 4, 2018 at 7:33 pm

     Is there a waiver for scooters & power chairs
     Manufactured in China
     To sell to the VA?
     National Contracts just awarded to two companies that have products manufactured in Main land China!!

   • 

     ColeyGSA on June 4, 2018 at 7:50 pm

     The VA TAA waivers usually apply to pharmaceutical contracts. Here is a link to their site with a little more information: TAA — Non-Availability Determinations under 65 I B

     If you have additional questions regarding a specific contract, you may reach out the Contracting Officer for more guidance.

2. 

   Paula Hance on August 1, 2017 at 1:55 pm

   Would territories of Australia be considered TAA compliant?

   Reply
3. 

   ColeyGSA on August 2, 2017 at 4:15 pm

   Australia including states and territories are included in TAA – Australian Capital Territory, New South Wales, Northern Territory, Queensland, South Australia, Tasmania, Victoria, and Western Australia.

   Reply
4. 

   Lisa on September 19, 2017 at 1:37 pm

   As a manufacturing company, if you assembly a unit in the U.S. and use only one small fraction for the product that is from a TAA non-compliant country (a locking mechanism)and the rest of the product material is from TAA compliant countries would the overall finished product still qualify as TAA compliant?

   Reply
   • 

     Julio Cardenas on September 19, 2017 at 2:17 pm

     **Updated**
     As long as 50 percent of the cost of manufacture occurs in a TAA designated country, it should be considered TAA Compliant.

   • 

     Jayson on June 3, 2018 at 1:58 am

     Does this include if your point of origin is say China but you can prove you assemble in the US and occur that 51% cost ? What if it is an OEM product ?

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     ColeyGSA on August 9, 2018 at 4:56 pm

     Components manufactured elsewhere that are a part of the total solution, no matter if it’s an OEM, may still be within the parameters of substantial transformation. It does sound like most of your components are made in China. What these components are and the purpose they serve may also affect the outcome of this test. Reach out to Coley if you need TAA help. We can provide an assessment of your specific situation for an hourly rate.

5. 

   Wayne Doyle on October 11, 2017 at 9:34 pm

   Nearly all disposable coveralls are manufactured in China. I see several companies on GSA selling coveralls that they claim are manufactured by a company who is a distributor only. The coveralls they distribute are from China. How are these companies able to sell Chinese coveralls on GSA?

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6. 

   Patrick M. on February 14, 2018 at 2:40 pm

   Hi! Great website and very informative. I am wondering about little Macedonia and when it might become a TAA designated county. Obviously it’s disputes with Greece and its internal fragility remain an issue, but I was wondering if there is movement with its application to join NATO, the EU, etc? We sell a product partially produced there and we are prevented from selling certain items due to this situation.

   Reply
   • 

     Julio Cardenas on February 14, 2018 at 7:47 pm

     Patrick, I am glad you like our site! TAA countries are those who have Trade Agreements with the US. Joint NATO is not a trade agreement that could provide TAA Designated Country status. However, the EU currently has trade agreements with the United States and therefore all the members are TAA compliant countries. We will continue to check the various sources listed at the end of this blog to keep our list of TAA Designated Countries up to date. Another thing to keep in mind is: substantial transformation. Verify if your product is “partially produced” in one country, and substantially transformed in a TAA designated country, it could still qualify as TAA compliant. Best of Luck!

7. 

   Greg Madden on May 23, 2018 at 4:50 pm

   I did not see the authority for the UAE to be considered as a designated country under the TAA. Is the UAE / Dubai in fact a designated country under the TAA? If so, what do they fall under? I know UAE is a member of the WTO, but they are not included as a member or observer to the GPA, correct? Any light you can share on UAE’s status as a (non) designated country would be appreciated.

   Reply
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     ColeyGSA on May 23, 2018 at 10:32 pm

     Thanks for reaching out regarding United Arab Emirates. Currently, the General Service Administration includes the UAE on their Designated Countries List. Per your request we did further research and could not verify the source for GSA doing so. The UAE is not included in the definitive list to be found in the Federal Acquisition Regulation (FAR) Subpart 25.4 You are correct in that the UAE is a WTO signatory, just not on an agreement that is incorporated in the elements required by the FAR. Based on our research UAE is non-TAA compliant country per the FAR definition.

8. 

   Cloud Pharma on June 18, 2018 at 10:30 am

   Dear Sir/Madam
   What is the situation for Turkey and Turkey Products We produce fish oil + omega supplements products
   Can the sales channel want to this request from us current we have register to the FDA for our all products

   Regards,

   Reply
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     ColeyGSA on June 18, 2018 at 4:39 pm

     Turkey is currently not on the list of Trade Agreements Act (TAA) approved countries. Although it is a member of North Atlantic Treaty Organization (NATO), it is currently not part of the World Trade Organization (WTO) agreement. There are a few countries that the Department of Veteran Affairs (VA) will provide wavers for pharmaceutical purposes, however, Turkey is not one of those listed.

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     Cloud Pharma on June 18, 2018 at 10:11 pm

     Thank you for interest.
     Is TAA compliance request for nutritional supplementation?
     for example; sale of the market and pharmacy sales So what should we do we have a chance to get a TAA compliance certificate for the company

     Regards,

   • 

     ColeyGSA on July 8, 2018 at 10:02 pm

     Check your contracts for FAR Clause 52.223-1. If found, Trade Agreements will apply and the product must comply with these approved countries of origin.

     For example. Nutritional and Dietary Supplements are within the scope of the VA’s 65 I B Pharmaceutical and Drug Federal Supply Schedule contract program. Trade Agreements is currently in full-effect and this product must originate from an approved TAA country.

9. 

   Stephane on August 3, 2018 at 7:35 am

   I do not see Mauritius on the list of TAA compliant country. Would the AGOA membership for Mauritius allow Mauritius to become a TAA compliant country?

   Reply
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     ColeyGSA on August 8, 2018 at 10:01 pm

     Unfortunately FAR 52.225-5 does not list Mauritius as a non-TAA compliant region. Further, the African Growth and Opportunity Act does not appear to be listed as an agreement that will bring Mauritius into TAA-compliance. The Trade Agreement Act changes periodically. Please frequent our site as we attempt to keep this page fresh with TAA-compliant countries.

10. 

    Dr Girish on August 3, 2018 at 12:19 pm

    Some of the new pharmaceutical ingredients (API) made in India ( Non TAA compliant country) by multinational companies and drug formulation is done in TAA compliant country. I it possible to get wavier in this case

    Reply
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      ColeyGSA on August 8, 2018 at 10:00 pm

      Yes, it is possible to obtain a waiver (TAA – Non-availability Determination) from your Contracting Officer and only applies to the VA Federal Supply Schedule. Specific requirements from the VA FSS as follows:

      TAA — Non-Availability Determination
      Special Item Number (SIN) 42-2A product items that are not U.S.-made or designated country end products must be offered for sale to the Government under an FSS 65 I B contract and must be listed as other end products, as required by Federal Acquisition Regulation (FAR) 52.212-3(g)(5)(ii). In accordance with FAR 25.403(c) & 25.103(b)(2), the decision has been made that the Contracting Officer may make an individual non-availability determination pursuant to 1) information provided by the offeror that neither the offered 42-2A product items nor similar or like items are mined, produced, or manufactured in the United States or a designated country in sufficient quantity to fulfill the requirements, and 2) in light of the requirement set forth in 38 U.S.C. Section 8126(a)(1) that manufacturers shall make available for procurement on the Federal Supply Schedule of the General Services Administration each covered drug of the manufacturer. Below outlines the process for offering these items to the Government under an FSS 65 I B contract via modification or via an Interim Agreement (IA), as applicable.

      Source: https://www.va.gov/opal/nac/fss/taa.asp#65ib

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      Dr Girish Dixit on September 3, 2018 at 10:38 am

      Thank you so much for clarification

11. 

    Matt on August 14, 2019 at 8:19 am

    We are manufacturer from China, producing Portable Air Conditioner, most of our parts came from China as well, so I want to know if our product is TAA compliant, and how would it influence our sales in US. Thank you.

    Reply
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      ColeyGSA on August 22, 2019 at 7:58 pm

      Hello Matt! If your parts, manufacturing, and assembly is happening in China, then it would appear that your products are not TAA Compliant. Here is some language directly from the FAR: “substantial transformation” (i.e., transforming an article into a new and different article of commerce, with a name, character, or use distinct from the original article).

      Non-TAA status does not impact regular commerce activity. Selling to the government is different. Below the $180K threshold, the Buy America Act applies. Below the micro-purchase threshold ($10,000) the acts do not apply. The exception is if there are no competitors (similar products) being manufactured in a designated country.

12. 

    Ray Spencer on August 21, 2019 at 7:25 pm

    We are importing the components for piece of medical equipment from China. After assembling here in USA we sell to doctors as a completed device with a new name. (microscope)
    Is that newly assembled device with a new name considered TAA compliant?

    Reply
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      ColeyGSA on August 22, 2019 at 5:55 pm

      Hello Ray, as specified in the blog, Customs and Border Protection (CBP) considers either that 50 percent of the cost of manufacture or location where product is “substantially transformed” is from/within a TAA Designated Country. Being that your product is assembled in the US, it would appear that substantial transformation is in the US and therefore TAA Compliant. The substantial transformation is based upon he question of whether the intended end use is possible without the value added in the United States through assembly, packaging, etc.

13. 

    Brian on December 5, 2019 at 4:55 pm

    Can a reseller of products in the United States rely upon a Taiwanese Certificate of Origin (COO) labeling, or does the reseller have to verify that the products are “substantially transformed” in Taiwan to be TAA compliant. It appears that Taiwan might have a different standard than the “substantially transformed” test and relies upon more of a value added test. In other words, will the United States recognize a COO from Taiwan for TAA complaince?

    Reply
    • 

      ColeyGSA on December 5, 2019 at 9:59 pm

      The reseller relies on the manufacturer to identify and monitor the Country of Origin. The reseller agreement should state that requirement.

14. 

    Burak on February 18, 2020 at 1:05 pm

    Hello, we are purchasing SKD Kits from Turkey and make the assembly in Poland. However, one of the component is the most expensive one and its origin is China.
    Since, we are making the final assembly in Poland, can we say that this product is TAA Compliant?

    Thanks,

    Reply
15. 

    Jerry Poole on May 20, 2020 at 2:24 am

    How do I find out about Cisco System devices that are made in China but designed and governed by US specifications. Are there any Cisco devices approved or on any type exception list?

    Reply
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      ColeyGSA on May 20, 2020 at 1:49 pm

      Jerry, we are not aware of any exception specifically for Cisco. You may want to reach out to them directly. Here are some links that may help: https://www.cisco.com/c/en/us/about/legal/global-export-trade/general-export-compliance.html https://news.bloomberglaw.com/federal-contracting/no-revival-for-buy-american-suit-involving-cisco-products

16. 

    Matthew Steele on June 15, 2020 at 5:44 pm

    Great information, thank you. I suspect we will be reaching out to you in the near future, but I have some immediate questions.

    We manufacture 2 small PCBAs in China. However we will move manufacturing to Taiwan and source as many components from TAA compliant countries as possible. Some of the components on the PCBAs will still be from China. It seems that if we move our PCBA manufacturing to Taiwan, and use as many TAA compliant sources as possible that the PCBAs are going to be TAA compliant. Is this true? One of the 2 PCBAs is assembled into a plastic button we manufacture and assemble in Taiwan.

    Also we source a small 12v water pump from China. We have already created a new pump mold to modify the pump body. This modification allows our PCBA (one the 2 I described above) to slide into the pump body and connect to the existing pump PCBA (Chinese). If this final assembly were moved to Taiwan would we be TAA compliant?

    Reply
17. 

    Barb Wert on April 29, 2021 at 4:48 pm

    If more than 50% of the cost of components in our product is from TAA-compliant countries, then the product is TAA compliant … is that correct?

    Reply
18. 

    Andrew Hsiao on August 20, 2021 at 6:02 am

    We’ll buy the PCBAs and mechanical parts from China and final assembly will be in Taiwan. Can I say the finished goods are TAA compliant ?

    Reply