Under normal circumstances, all products on the GSA Schedule must be Trade Agreement Act (TAA) compliant. That means they must be manufactured or substantially transformed in the United States or a TAA designated country. On April 3, 2020, GSA’s Senior Procurement Executive, Jeffrey Koses, issued a memo that allows certain non-TAA products to be temporarily added and sold through the GSA Schedule in response to COVID-19 customer demands.
The memo notes, “GSA is taking an unusual step to make sufficient resources available. The needs of all levels of government both U.S. and worldwide have increased greatly for certain critical and essential supply items. GSA has determined that there is not a sufficient available supply of these items from trade agreement compliant sources. Nor is there sufficient availability under the Buy American statute clause.”
Notes on GSA’s TAA Exception Memo for COVID-19
You can read the full memo here, however below are a few highlights:
- Non-TAA compliant products are only available for orders supporting the government’s COVID-19 response efforts.
- Products manufactured in countries listed in FAR 25.7 are not covered under this exception and will not be allowed on the GSA Schedule (Cuba, Iran, Sudan, Burma, and North Korea).
- Non-TAA compliant products must be clearly identified as such when responding to RFQ’s.
- The temporary exception to non-TAA compliant products is in effect until July 1, 2020 unless extended by GSA.
- Due to the short duration of the exception, companies may only add non-TAA complaint products to existing GSA Schedule Contracts; GSA will not award a new GSA Schedule for non-TAA compliant products.
What Products Are Allowed Under the Temporary TAA Exception?
This list may change in order to maintain sufficient quantities of available products. However, the original notice temporarily allows non-TAA products under the following Federal Supply Classes (FSCs):
- FSC 4240 N95 masks
- FSC 6810 Sodium Hypochlorite (bleach)
- FSC 6840 Disinfectants includes, cleaners, sprays, and wipes
- FSC 7930 Cleaners including sanitizing surface and floor cleaners
- FSC 8520 Hand Sanitizers, soaps, and dispensers
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