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RE:[sap-log-mm] Best method for multiple country of origin

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Posted by Legal_Geek
on Oct 12 at 7:28 PM
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Buy American Act requires certification of product as Foreign or Domestic in accordance with specific guidelines. A two-part test is used to identify "domestic end products" The end product (i.e., article, material or item of supply being purchased under the prime contract for public use) must be manufactured in the US, AND Manufacture must be meaningful. The cost of domestic components must exceed 50 percent of the cost of all direct components of the end product. Both tests must be satisfied for the given "end product" to qualify as a "domestic end product".

So for the latter part of the test (content test) you need to know the COO of all of the components going into the end assembly. If you buy from multiple countries, you would need to know not only that you have multiple countries, but which countries. Under the regulations, parts from specific (qualified) countries can be calculated within your domestic percentage You would need to have a field that is accessible for data pull (not a text field).

When going outside of the U.S. for your supply, dependent upon the country, you may need to certify from a qualifying country. Or you may need to determine it is foreign.

You also need the data because there is the Trade Agreements Act which can provide exception in that if you are supplying from specific (ie. designated) countries, under specific circumstances, you can supply the part as foreign, but with an TAA exception, so no penalty would exist in your bid.

And finally, there are TAA prohibited countries. You need the specifics to know if you can sell to the defense and space industry.

If you do not segregate your hardware by part/sku number or batch, AND cannot guarantee that you can provide domestic supply, then you must either certify as foreign, and take the penalties in your bid that come with it.

Best method is a combined process and it solution. I was just wondering if anyone had been working a specific IT/SAP solution yet.
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