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I am currently researching several different opinions on what is or should be TAA Compliant for Commercial IT equipment/parts. I am working for a DOD Contractor supporting a DoD legacy system. Even though the vendor is an American company, much of what's inside of the systems are parts that manufactured in a non-TAA designated country, however, the overall system is assembled in a TAA recognized country. There has been much discussion since I have been added to the team whether buying individual parts to stock on our warehouse shelves for spares is legal...meaning, meeting TAA compliance standards. The government customer has agreed if the company replaces the part under warranty, this is TAA compliant. However, if we buy the exact same part from the company and store it for future use as a spare, it is no longer TAA compliant, even though we are replacing the same part as the warranty. 

If commercial IT is exempt from the BAA, then are we in compliance if we buy the same part from the vendor for future replacement of a part that is already considered TAA compliant?  

Thank you to whomever can help me navigate this dilemma. 

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Have you considered seeking the advice of an attorney who is knowledgeable in these matters?  

It sounds like your government customer has already given you an answer.  I'm not sure of the validity of the answer, as I have never thought of a warranty having any impact of TAA compliance -- are you looking here for information to challenge your government customer's answer?

TAA compliance is a very messy area, and even experts will come to different answers with seemingly similar facts.

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1 hour ago, ji20874 said:

Have you considered seeking the advice of an attorney who is knowledgeable in these matters?  

It sounds like your government customer has already given you an answer.  I'm not sure of the validity of the answer, as I have never thought of a warranty having any impact of TAA compliance -- are you looking here for information to challenge your government customer's answer?

TAA compliance is a very messy area, and even experts will come to different answers with seemingly similar facts.

Good advice.  @brian1970 I do like doing initial research on questions posed in Forum.   I found this that might help you, not specifically, but to wrap your arms around the whole of TAA.

 

 

 

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