Buy American Act compliance
Buy American Act compliance sits at the center of Trade and Geopolitical Risk right now, with the U.S. Department of Defense and the Federal Acquisition Regulatory Council tightening domestic content thresholds under FAR Part 25 and the January 2022 final rule that raised the domestic content requirement to 60 percent, with a path to 75 percent by 2029. The U.S. Trade Representative holds parallel authority over waiver conditions and reciprocal trade agreement exceptions that directly affect how multinational suppliers qualify components. Compliance teams are actively re-mapping bill-of-materials documentation and vendor certifications against the stepped thresholds before each contract renewal cycle.
Watch
- FAR Part 25 domestic content threshold stepping to 65 percent in 2024
- DoD class deviation waivers: which product categories still qualify and for how long
- USTR reciprocal agreement exceptions that offset BAA requirements for allied-nation suppliers
- End-product vs. component-level certification disputes surfacing in GAO bid protests
Recent material activity in Trade & Geopolitical Risk
A selection of recent published briefs; this is not a complete archive.
OFAC adds entities to Non-SDN Menu-Based Sanctions List under PAIPA with blocking and financial prohibitions
OFAC added entities to its Non-SDN Menu-Based Sanctions List on October 19, 2026 under the Protecting American Intellectual Property Act of 2022. The designations impose blocking, lending, foreign exchange, and banking t…
Read a full sample brief →DGFT amends trade procedures to activate TRQ allocation mechanism under the India-New Zealand Free Trade Agreement
India's Directorate General of Foreign Trade (DGFT) issued Public Notice No. 33/2026-27 on October 17, 2026, amending the Handbook of Procedures, 2023 to incorporate tariff-rate quota (TRQ) procedures under the India-New…
Read a full sample brief →India's Ministry of Finance issues first-tranche tariff concessions under the India-New Zealand Free Trade Agreement
India's Ministry of Finance, Department of Revenue, issued Notification 32/2026-Customs on October 16, 2026, granting customs duty exemptions on goods imported from New Zealand. The notification gives effect to the first…
Read a full sample brief →China's Ministry of Commerce and Ministry of Science and Technology propose expanded technology export controls covering AI, biomedical, and energy storage sectors
China's Ministry of Commerce and Ministry of Science and Technology issued Announcement No. 48 of 2026 on October 16, 2026, opening a public consultation on proposed amendments to the Catalogue of Technologies Prohibited…
Read a full sample brief →CBP releases Harmonized System Update 2625 with Section 232 pharmaceutical tariff records and CPSC flagging changes
CBP issued Harmonized System Update (HSU) 2625 on September 29, 2026, containing 57 harmonized tariff records and 304 Automated Broker Interface records. The update incorporates Section 232 pharmaceutical tariff changes,…
Read a full sample brief →Canada's trade tribunal finds reasonable indication of injury from Chinese paperboard cups and containers dumping
The Canadian International Trade Tribunal (CITT) issued a determination on October 16, 2026, under preliminary injury inquiry PI-2026-004, finding a reasonable indication that dumping and subsidizing of paperboard cups a…
Read a full sample brief →Commerce issues final affirmative countervailing duty determination on high purity dissolving pulp from Brazil
The U.S. Department of Commerce issued a final affirmative countervailing duty determination on October 16, 2026, covering producers and exporters of high purity dissolving pulp from Brazil. The determination finds that …
Read a full sample brief →Commerce issues final affirmative LTFV determination for high purity dissolving pulp from Brazil
Commerce issued a final affirmative determination on October 16, 2026, finding that high purity dissolving pulp from Brazil is being sold, or is likely to be sold, in the United States at less than fair value. The period…
Read a full sample brief →Commerce issues final affirmative antidumping determination on high purity dissolving pulp from Norway
The U.S. Department of Commerce issued a final affirmative determination on October 16, 2026, finding that high-purity dissolving pulp from Norway is being sold, or is likely to be sold, in the United States at less than…
Read a full sample brief →USITC declines to review ALJ order adding dependent patent claims to GlobalFoundries semiconductor investigation
The USITC has declined to review an initial determination that allows GlobalFoundries U.S. Inc. to amend its complaint in an active Section 337 investigation. The amendment adds dependent claims 8 through 12 and 19 of U.…
Read a full sample brief →