What is TAA Compliance?

(Updated: May 2021 )

How do you know if you are TAA Compliant? TAA refers to the Trade Agreement Act. Under 19 USC 2501 Trade Agreements Act government agencies may only purchase US-made or designated country end products or US or designated country services.

Are Your Products on GSA Schedule TAA Compliant?

Because the estimated value of a GSA schedule exceeds $191,000, all GSA product sales must be Trade Agreement Act (TAA) compliant, as per FAR 52.225-5. In order to be TAA compliant, 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.

If you offer services through your GSA Schedule, the TAA may also apply to you; but that is not always the case. The issue of how the TAA applies to services is a complex one.

How to Determine if products were “Substantially Transformed?”

If a product is completely manufactured in the United States or in a TAA designated country, you are TAA compliant. Software country of origin is determined in the country where the software was compiled.

Sometimes a product requires assembly in several countries or has components from various countries; the TAA compliance becomes murkier and a determination of where the product is substantially transformed is required. If a product is manufactured in various countries, the final product must be “substantially transformed” in a designated country. Substantial transformation would be transforming an article into a new and different article of commerce, with a name, character, or use distinct from the original article. (refer to FAR 25.001(c))

Responsibility falls wholly on the government contractor, to determine if a product has been substantially transformed. More information on International Trade: Rules of Origin available here: http://www.fas.org/sgp/crs/row/RL34524.pdf.

Who Makes the Determination of TAA Compliance?

The U.S. Customs and Border Protection states that “the responsibility for making a determination of substantial transformation rests solely with the contractor. The contractor can go to The Office of Regulations and Rulings within U.S. Customs and Border Protection, which is the Federal agency responsible for making substantial transformation determinations or giving their opinions.”

How to Keep Your GSA Schedule TAA Compliant?

First you must have a system in place that periodically verifies that the products being offered under your GSA schedule are TAA compliant. Furthermore, if you are not a manufacturer, we recommend that you verify countries of origin quarterly or, at minimum, with catalog updates from your suppliers to verify that products are still being manufactured or “substantially transformed” in a TAA designated country.

If your manufacturing source changes during the term of your contract and items are now manufactured in a non-designated country, your products will consequently be out of compliance. You must immediately take action to remove the non-TAA compliant items from your GSA Schedule. A GSA consultant from the Coley team can assist with getting this processed.

TAA Designated Countries are regularly updated and can be accessed from here:  FAR-Clause-52.225-5. Also, as noted on our table below, if a product is manufactured in China, Indonesia, Malaysia, or Sri Lanka, you may be permitted to sell them, but only to the VA with a required waiver. Territories belonging to the United States, are TAA compliant therefore, American Samoa, Northern Mariana Islands, Puerto Rico, and the United States Virgin Islands are compliant countries.

Current List of TAA Compliant Countries Include:


AfghanistanDenmarkLatviaSao Tome and Principe
Antigua and BarbudaDominicaLiberiaSierra Leone
ArmeniaDominican RepublicLiechtensteinSingapore
ArubaEl SalvadorLithuaniaSint Eustatius
AustraliaEquatorial GuineaLuxembourgSint Maarten
AustriaEritreaMadagascarSlovak Republic
BahrainEthiopiaMaliSoloman Islands
BarbadosFranceMauritaniaSouth Sudan
BelizeGermanyMoldova*Saint Kitts and Nevis
BeninGreeceMontenegroSaint Lucia
BhutanGrenadaMontserratSaint Vincent and the Grenadines
British Virgin IslandsGuatemalaMozambiqueSwitzerland
Burkina FasoGuinea BissauNetherlandsTanzania U.R.
BurundiGuyanaNew ZealandTimor- Leste (East Timor)
CanadaHondurasNigerTrinidad & Tobago
Central African RepublicHong KongNorwayTuvalu
ColombiaIrelandPeruUnited Kingdom
ComorosIsraelPoland**United States of America
Democratic Republic of the CongoItalyPortugalVanuatu
Costa RicaJamaicaRomaniaYemen
CyprusKorea, Republic of (South)
Czech RepublicLaos

**Includes all US Territories: Puerto Rico, US. Virgin Islands, Guam, American Samoa and Northern Mariana Islands.


Non-TAA Compliant Countries List Below:

*FAR 52.225-5 (Reviewed: June 2019); Federal Acquisition Regulation , Trade Agreements.


AlbaniaGeorgiaMarshall IslandsSeychelles
AlgeriaGhanaMauritiusSri Lanka
AzerbaijanIndonesiaMonacoSouth Africa
Bosnia and HerzegovinaJordanNamibiaSyria
Brunei DarussalamKorea, NorthPakistanTonga
Cape VerdeKuwaitPapua New GuineaTurkey
Cote d’IvoireLebanonPhilippinesUnited Arab Emirates
EcuadorMacaoRepublic of CongoUzbekistan
FijiMalaysiaSaudi ArabiaVietnam


VA only – Waiver Required

The VA is in charge of the healthcare related Federal Supply Schedules (FSS.)There may be some instances where certain healthcare related products needed to save lives are only manufactured in non-TAA compliance countries including China. You must obtain a TAA Waiver from a Contracting Officer before you can add any non-TAA compliant products to your Schedule. The letter must state that the product is necessary and that they are providing a waiver of the TAA for a particular contract or task order.

The VA is currently processing Non-Availability Waiver Determinations under the VA’s 65 I B Pharmaceutical and Drugs Schedule program.  Furthermore, these waiver requests can only be processed for products falling under the scope of Special Item Number 42-2A Single source drug, innovator multiple source drug, and any biological product identified under Section 600.3 of Title 21, CFR.


Sri LankaThailand

World Trade Organization
GSA Vendor Support
VA – Office of Acquisition and Logistics  
FAR 25. 4 Acquisition.gov  
FAR 25.225-5 Acquisition.gov
Harmonized Tariff Schedule of the United States


*FAR Case 2016-009; New Designated Countries Effective as of October 31, 2016 for Moldova and Ukraine


  1. Ann

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


    • Julio Cardenas

      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

      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

      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

    Would territories of Australia be considered TAA compliant?

  3. ColeyGSA

    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.

  4. Lisa

    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?

    • Julio Cardenas

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

    • Jayson

      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 ?

    • ColeyGSA

      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

    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?

  6. Patrick M.

    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.

    • Julio Cardenas

      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

    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.

    • ColeyGSA

      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

    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


    • ColeyGSA

      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.

    • Cloud Pharma

      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


    • ColeyGSA

      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

    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?

    • ColeyGSA

      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

    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

    • ColeyGSA

      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

    • Dr Girish Dixit

      Thank you so much for clarification

  11. Matt

    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.

    • ColeyGSA

      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

    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?

    • ColeyGSA

      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

    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?

    • ColeyGSA

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

  14. Burak

    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?


  15. Jerry Poole

    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?

  16. Matthew Steele

    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?

  17. Barb Wert

    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?

  18. Andrew Hsiao

    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 ?


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