Client Alerts & Newsletters

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.

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

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

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

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

Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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