By Uniqcli Team
Under the Trade Agreements Act, a "designated country" is a country whose products a federal agency may buy when the TAA applies to the purchase. FAR 25.003 defines the term as four separate groups combined: World Trade Organization Government Procurement Agreement (WTO GPA) countries, Free Trade Agreement countries, least developed countries, and Caribbean Basin countries. An item that is wholly the growth, product or manufacture of one of those countries — or of the United States — or that was substantially transformed in one of them, is a designated country end product.
The lists below are transcribed from FAR 25.003 and clause 52.225-5 as published at acquisition.gov, in the text current as of August 2026 (page state FAC 2026-01, effective March 13, 2026). They are not permanent. Countries accede to the GPA, trade agreements are signed and amended, and least developed countries graduate off the United Nations list, so the FAR text is periodically updated. Treat this page as a reference for reading a quote, and confirm the current lists at acquisition.gov before you write a country name into a requirement or a determination.
What "designated country" means in FAR 25.003
The definition is a union, not a hierarchy: a country qualifies if it sits in any one of the four groups, and several countries sit in two. Australia, Korea and Singapore appear under both the WTO GPA and the Free Trade Agreement lists; Aruba appears under both the WTO GPA and Caribbean Basin lists; Haiti appears under both the least developed and Caribbean Basin lists. Nothing turns on which group a country reaches the list through — designated is designated.
The parallel category is the U.S.-made end product, which is defined separately and is not part of the designated-country lists. When the TAA applies to an acquisition, the ordinary result is that the agency may buy U.S.-made end products and designated country end products, and may not buy end products from anywhere else. That is the whole practical shape of the rule: a two-column world, with the lists below defining the second column.
One thing the lists do not tell you is where a specific product came from. The country of origin of an end product is a determination about that item — where it was manufactured, or where it was substantially transformed into a new and different article of commerce. The lists tell you which answers are acceptable; they cannot tell you what the answer is for a given part number.
Group 1 — WTO Government Procurement Agreement countries (47)
Armenia, Aruba, Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hong Kong, Hungary, Iceland, Ireland, Israel, Italy, Japan, Korea (Republic of), Latvia, Liechtenstein, Lithuania, Luxembourg, Malta, Moldova, Montenegro, Netherlands, New Zealand, North Macedonia, Norway, Poland, Portugal, Romania, Singapore, Slovak Republic, Slovenia, Spain, Sweden, Switzerland, Taiwan, Ukraine and the United Kingdom.
This is the group most federal IT hardware arrives through. It covers the European Union member states individually, the United Kingdom, Canada, Japan, Korea, Israel, Taiwan, Hong Kong, Singapore, Australia and New Zealand — which between them account for a large share of the manufacturing and final-assembly locations that appear on enterprise networking, storage and power equipment. Taiwan's presence on this list is the single most consequential entry for IT buyers, and it is covered in more detail below.
Group 2 — Free Trade Agreement countries (17)
Australia, Bahrain, Chile, Colombia, Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Korea (Republic of), Mexico, Morocco, Nicaragua, Oman, Panama, Peru and Singapore.
Australia, Korea and Singapore already appear in group 1, so the entries that genuinely widen the designated set here are the Bahrain, CAFTA-DR (Costa Rica, Dominican Republic, El Salvador, Guatemala, Honduras, Nicaragua), Chile, Colombia, Morocco, Oman, Panama, Peru and USMCA partners. Mexico reaches the designated lists through this group, which is why it is designated even though it is not a WTO GPA country. The relevant detail for a buyer is that the free trade agreements carry their own dollar thresholds, which are generally lower than the WTO GPA threshold.
Group 3 — Least developed countries (47)
Afghanistan, Angola, Bangladesh, Benin, Bhutan, Burkina Faso, Burundi, Cambodia, Central African Republic, Chad, Comoros, Democratic Republic of Congo, Djibouti, Equatorial Guinea, Eritrea, Ethiopia, Gambia, Guinea, Guinea-Bissau, Haiti, Kiribati, Laos, Lesotho, Liberia, Madagascar, Malawi, Mali, Mauritania, Mozambique, Nepal, Niger, Rwanda, Samoa, Sao Tome and Principe, Senegal, Sierra Leone, Solomon Islands, Somalia, South Sudan, Tanzania, Timor-Leste, Togo, Tuvalu, Uganda, Vanuatu, Yemen and Zambia.
This group rarely decides an IT purchase, because very little enterprise IT equipment is manufactured or substantially transformed in these countries. It matters for completeness: when someone asserts that a country "is not TAA," the claim has to be checked against all four groups, and this is the group most often skipped. It is also the group that changes most often, since graduation from the United Nations least developed country category removes a country from it.
Group 4 — Caribbean Basin countries (21)
Antigua and Barbuda, Aruba, Bahamas, Barbados, Belize, Bonaire, British Virgin Islands, Curacao, Dominica, Grenada, Guyana, Haiti, Jamaica, Montserrat, Saba, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, Sint Eustatius, Sint Maarten and Trinidad and Tobago.
As with group 3, this list is seldom the deciding factor on an IT line item, and two of its entries — Aruba and Haiti — are already designated through another group. Read it as part of the definition rather than as a sourcing map.
Countries that do not appear on any of the four lists
The following countries do not appear in any of the four groups above, and are therefore not designated countries under FAR 25.003 as of August 2026: China, India, Russia, Malaysia, Thailand, Vietnam, Indonesia, the Philippines, Brazil, Turkey, Pakistan, Sri Lanka and South Africa.
State that carefully, because the distinction is real. Absence from the FAR 25.003 lists is not a sanction, an embargo, or a general prohibition on importing from those countries — it is a statement about which end products an agency may buy when the Trade Agreements Act applies to that acquisition. Products from non-designated countries are bought lawfully every day on acquisitions the TAA does not reach, and on acquisitions where an exception or a waiver applies. What the absence means, on a TAA-covered buy, is that an end product of that country is not an acceptable answer to the origin question.
The practical consequence for IT is concentrated in one place. A very large share of the world's electronics manufacturing capacity sits in countries that are not on these lists, which is why manufacturers maintain separate designated-country production or final-assembly lines for the federal market, and why two units of the same product family under the same brand can carry different origins. Origin is a property of the specific part number and its build, not of the brand on the bezel.
The three cases buyers get wrong
Taiwan is designated. It appears on the WTO GPA list in FAR 25.003 and clause 52.225-5, and given how much enterprise networking, server, power and storage hardware is made or substantially transformed there, this single entry resolves a large fraction of real federal IT sourcing questions. Buyers who assume otherwise routinely disqualify products that are in fact acceptable.
Mexico is designated. It is not a WTO GPA country, so a search of that list alone comes back empty and the wrong conclusion follows. Mexico reaches the designated lists through the Free Trade Agreement group. This is exactly the failure mode the four-group structure creates, and the reason a negative answer is only trustworthy after all four lists have been checked.
Thailand is not designated. It appears on none of the four lists, which surprises buyers because Thailand is a substantial electronics and storage-component manufacturing location and sits alongside designated countries in the same supply chains. Neighbouring geography, regional trade blocs and shared assembly networks confer nothing here — the only thing that matters is whether the country's name appears in FAR 25.003.
Substantial transformation: why the factory address is not the answer
An end product qualifies as a designated country end product if it is wholly the growth, product or manufacture of the United States or a designated country, or if it is substantially transformed in the United States or a designated country into a new and different article of commerce with a name, character or use distinct from the article or articles it was made from. That second branch is what makes the lists usable in a real supply chain, and also what makes origin harder to eyeball.
The test is about transformation, not effort or expense. Assembling a chassis from components that were themselves made elsewhere can meet it, if what emerges is genuinely a new and different article of commerce. Repackaging, relabelling, kitting, testing, adding a manual, or loading firmware onto an otherwise finished device generally does not. Neither does the address the goods were shipped from, the country in the vendor's business registration, or the country printed on the outer carton.
Two habits follow. Ask about the end product's country of origin rather than about a component's, since the determination is made at the level of the item being sold. And treat the manufacturer as the source of the answer — origin is the manufacturer's determination about its own build, and it is the manufacturer that certifies it.
When the list actually decides a purchase
The lists matter only on acquisitions the Trade Agreements Act reaches, and that is a threshold question. On an open-market buy, TAA generally attaches at or above the applicable trade agreement threshold — as of August 2026 the WTO GPA supply threshold is $174,000, set for calendar years 2026 through 2027 by the U.S. Trade Representative and implemented in FAR subpart 25.4. Several free trade agreements carry lower thresholds of their own, so the governing number depends on which agreement is in play.
Purchases made under a GSA Multiple Award Schedule contract work differently, and this is the point most often misread. GSA states that the TAA applies to MAS contracts unless the solicitation or contract says otherwise, and because the threshold is tested against the value of the contract rather than the value of an individual order, the origin rule reaches orders regardless of their dollar value. A small order placed against a Schedule contract is still governed by the origin rule; a small open-market purchase generally is not. That is regulatory context about how the buyer's own acquisition is structured, and the contracting officer's determination governs.
One rule ignores all of this. Section 889 of the FY2019 National Defense Authorization Act has no dollar threshold at all and applies to every acquisition, including micro-purchases and commercial off-the-shelf items. It also asks a different question: not where an item was made, but who made it. A product can be an entirely proper designated country end product and still be prohibited under §889, and the reverse is equally possible — which is why the two checks have to be run separately on the same line item.
How to check origin on a specific line item
Start at the source. Confirm the current lists at acquisition.gov — FAR 25.003 for the definition and clause 52.225-5 for the clause text an agency actually incorporates — rather than from a summary, this page included. Note the date you checked and the FAR revision the page was serving, because that is what makes your file defensible later.
Then get the origin for the exact part number, not the product family. Manufacturers publish country-of-origin information per SKU and revise it when production moves, and it is common for two configurations under one model name to differ. Where a manufacturer's own product title or documentation designates a specific model as TAA-compliant, that designation is the manufacturer's statement about its own build — read it as such, record which model it attaches to, and keep the document.
Finally, keep the questions separate in your file: country of origin under the TAA, covered-entity status under §889, and any cryptographic or configuration requirements are three independent checks, and passing one says nothing about the others. On quoted line items, Uniqcli performs TAA country-of-origin screening before the quote.
Key takeaways
- FAR 25.003 defines a designated country as any country in one of four groups — WTO GPA, Free Trade Agreement, least developed, or Caribbean Basin — and several countries appear in two of them.
- As of August 2026 the groups hold 47 WTO GPA countries, 17 FTA countries, 47 least developed countries and 21 Caribbean Basin countries, per FAR 25.003 and clause 52.225-5 at acquisition.gov.
- Taiwan is designated (WTO GPA) and Mexico is designated (Free Trade Agreement); Thailand is not designated — these are the three cases federal IT buyers most often get wrong.
- China, India, Russia, Malaysia, Thailand, Vietnam, Indonesia, the Philippines, Brazil, Turkey, Pakistan, Sri Lanka and South Africa do not appear on any of the four lists — an absence from the FAR lists, not a sanction or an import ban.
- Origin is decided by manufacture or substantial transformation into a new and different article of commerce — not by the shipping address, the vendor's country, or the carton label.
- The lists only bind where the TAA reaches the acquisition: as of August 2026 the WTO GPA supply threshold is $174,000 for calendar years 2026-2027, while Section 889 applies at every dollar value and asks a different question.
- The lists are amended as countries accede, trade agreements change and least developed countries graduate — confirm the current text at acquisition.gov before relying on any copy of it, including this one.
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Frequently asked
- What is a TAA designated country?
- It is a country listed in FAR 25.003 as belonging to one of four groups: World Trade Organization Government Procurement Agreement countries, Free Trade Agreement countries, least developed countries, or Caribbean Basin countries. When the Trade Agreements Act applies to an acquisition, an agency may generally buy U.S.-made end products and end products of those designated countries. A country only has to appear in one of the four groups, and several appear in two.
- Is Taiwan a TAA designated country?
- Yes. As of August 2026 Taiwan appears on the WTO Government Procurement Agreement list in FAR 25.003 and in clause 52.225-5, which makes it a designated country. This is the entry that resolves the largest share of federal IT sourcing questions, because a great deal of enterprise networking, server, storage and power hardware is manufactured or substantially transformed there. Confirm the current list at acquisition.gov before relying on it in a determination.
- Is China a TAA designated country?
- No. As of August 2026 China does not appear in any of the four groups in FAR 25.003, so an end product of China is not a designated country end product. That is a statement about which end products may be bought when the Trade Agreements Act applies to an acquisition — it is not a sanction, an embargo, or a general prohibition on goods from China, and it is a separate question from Section 889 of the FY2019 NDAA, which names specific companies and applies at every dollar value.
- Is Mexico TAA compliant?
- Mexico is a designated country as of August 2026, but it reaches the lists through the Free Trade Agreement group rather than the WTO Government Procurement Agreement group — which is why searching the GPA list alone returns nothing and produces the wrong answer. Note the wording, too: a country is designated, while an end product is or is not a designated country end product depending on where that specific item was manufactured or substantially transformed.
- Is Thailand a TAA designated country?
- No. As of August 2026 Thailand does not appear on any of the four lists in FAR 25.003. It surprises buyers because Thailand is a significant electronics and storage-component manufacturing location and sits in the same regional supply chains as several designated countries, but regional proximity and shared assembly networks confer nothing under the rule. Only the presence of the country's name in FAR 25.003 matters.
- Does the TAA designated country list change?
- Yes, and that is the main reason to check a primary source rather than a copy. Countries accede to the WTO Government Procurement Agreement, free trade agreements are signed and amended, and countries graduate off the United Nations least developed country list, each of which is reflected in an update to the FAR text. The list on this page reflects FAR 25.003 and clause 52.225-5 as published at acquisition.gov and current as of August 2026; confirm the current text there before writing a country name into a requirement.
- Does TAA apply to every federal purchase?
- No. The Trade Agreements Act reaches an acquisition when the applicable trade agreement threshold is met — as of August 2026 the WTO Government Procurement Agreement supply threshold is $174,000 for calendar years 2026-2027, with several free trade agreements carrying lower thresholds. Purchases under a GSA Multiple Award Schedule contract are the common exception buyers miss, because the threshold is tested against the contract rather than the individual order, so the origin rule reaches orders regardless of their value. Your contracting officer's determination governs.
- How do I confirm a specific product's country of origin?
- Ask the manufacturer for the country of origin of the exact part number you intend to buy, not the product family, and keep the document. Origin is the manufacturer's determination about its own build, it is made at the end-product level, and it changes when production moves — so two configurations sharing a model name can differ. Where a manufacturer designates a specific model as TAA-compliant in its own product title or documentation, that is the manufacturer's statement about that model, and it should be recorded against that model rather than generalized to the brand.
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