For decades, peer-policing for Trade Agreement Act (TAA) compliance on GSA Schedules has been the rule. Recently, GSA stated that there has been continued re-occurrence of non-TAA compliant products being listed and sold on the GSA schedule – a direct violation of the TAA and GSA Schedule contract terms. Consequently, GSA is taking action to clean up the proliferation of non-TAA compliant products on GSA Schedule and has issued a notice to vendors requiring a mandatory and time sensitive TAA reconciliation and contract modification.

Currently, the TAA reconciliation applies to the following GSA Schedules, but they can soon expand to more:

• Schedule 56: BUILDINGS AND BUILDING MATERIALS/INDUSTRIAL SERVICES AND SUPPLIES
• Schedule 66: SCIENTIFIC EQUIPMENT AND SERVICES
• Schedule 73: FOOD SERVICE, HOSPITALITY, CLEANING EQUIPMENT AND SUPPLIES, CHEMICALS AND SERVICES
• Schedule 84: TOTAL SOLUTIONS FOR LAW ENFORCEMENT, SECURITY, FACILITIES MANAGEMENT, FIRE, RESCUE, CLOTHING, MARINE CRAFT AND EMERGENCY/DISASTER RESPONSE

How to Remain TAA Compliant?

Get familiar with the different conditions that makes a product compliant with TAA.  To remain compliant and prevent GSA from removing your GSA Schedule pricelist from GSA eLibrary and GSA Advantage, all affected vendors must take the following actions by the response date:

1. Submit a spreadsheet that verifies the Country of Origin (COO) for each product approved on your GSA contract.
2. For all compliant products provide a copy of the Certificate of Origin OR certification from manufacturer on official letterhead verifying the product(s) they supply are compliant with Trade Agreements Act.
3. For all non-compliant products, a deletion modification must be completed and submitted immediately.
4. Updated pricelists should be sent to National Schedules Information Center at service@gsa.gov

For 15 years, we have made TAA compliance a critical part of our services and have kept clients compliant.  This action is included free of charge for Coley’s annual GSA contract management clients. If you are not an existing client, Coley can assist you with a project-based fee.

If you would like help complying with the mandated action, or have question regarding TAA compliance, identifying Country of Origin, the meaning of “Substantial Transformation,” of other factors related to the TAA, contact Coley.