GSA Implements TAA Compliance Re-Certification
On May 5th, 2016, The General Services Administration (GSA) released a letter to all current GSA Schedule contract holders in regards to failed compliance with the Trade Agreements Act (TAA). Under the TAA, only products manufactured in the U.S. and certain other TAA approved countries are allowed to be sold under a GSA Contract. According to the GSA, there have been far too many instances of non-compliance which as a result has diminished the integrity of GSA Advantage! and Multiple Award Schedules (MAS) contracts. In order to maintain veracity, the GSA has taken immediate action in order to thwart TAA non-compliance and restore reliability.
Root Causes of the Re-Certification
On May 3rd, 2016, U.S. Representative Richard Hanna, Chairman of the House Small Business Subcommittee on Contracting and the Workforce, initiated a call for an investigation into the abuse of the “Made in America” label on government websites that misrepresent the Country of Origin (COO) of vendor products. A press release made by the U.S. House of Representatives cites a particular case where a manufacturer’s verified “Made in America” products were being listed beside misrepresented imported products. Rep. Hanna stated that, “with the increasing scarcity of small domestic manufacturers in the United States, it is vital that GSA ensures that this important distinction not be applied indiscriminately and without proper verification…. The phrase ‘Made in America’ signals much more than a product that is made domestically. It is a clear representation of the quality and refinement of products made in the U.S.” Further into his statement, Rep. Hanna suggests that a revision of the COO verification process should include pre-emptive actions in order to prevent non-compliant products from being uploaded to GSA Advantage! prior to acceptance.
Call to Action of GSA Schedule Contract Holders
All contractors should review their current GSA pricelist to ensure that the products listed, and self-certifications provided, accurately state the applicable Trade Agreements Act designated country for each product, per FAR Clauses 52.225-5 and 52.212-3(g)(5) Trade Agreements Certificate. If you are a reseller, you may need to confer with the manufacturer. If you identify products from a non TAA designated country, you must prepare and submit a Deletions Modification request. If you find that the TAA designated country listed for a product is inaccurate, but the product is still TAA compliant, upload a revised pricelist to GSA Advantage! For assistance with a response to the TAA compliance letter, uploading a deletions modification and/or uploading a new pricelist (catalog file) to GSA Advantage!, please contact BH Sky Associates for immediate assistance.
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