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
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OFAC replaces legal-services payment reporting requirement with recordkeeping obligation across multiple sanctions programs
On July 27, 2026, OFAC issued a final rule updating contact and website information across several sanctions-program regulations and amending general licenses that authorize payments for legal services from funds origina…
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USITC opens public interest comment period for Section 337 complaint targeting secondary cylindrical batteries and components
On July 27, 2026, the U.S. International Trade Commission received a complaint covering certain secondary cylindrical batteries, their components, and downstream products containing them, docketed as DN 3926. The Commiss…
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ITC institutes Section 337 investigation into imported dermatological treatment devices on four patent claims
The U.S. International Trade Commission instituted an investigation on July 27, 2026, following a complaint filed by Serendia, LLC of Los Angeles alleging patent infringement by importers of dermatological treatment devi…
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ITC institutes Section 337 investigation into adjustable child carriers on patent infringement complaint by Ergobaby
The U.S. International Trade Commission formally instituted an investigation on July 27, 2026, into alleged patent infringement by importers of adjustable child carriers, following a complaint filed by The Ergo Baby Carr…
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ITC institutes Section 337 investigation into imported silicon anode materials covering four active battery patents
The U.S. International Trade Commission instituted an investigation on July 24, 2026, based on a complaint filed June 18, 2026 by Sila Nanotechnologies and Georgia Tech Research Corporation. The complaint alleges patent …
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USTR publishes FY 2027 tariff-rate quota allocations for raw cane sugar, refined sugar, and sugar-containing products
On July 24, 2026, the Office of the United States Trade Representative issued FY 2027 in-quota quantity allocations for imported raw cane sugar, refined sugar (including specialty sugar), and sugar-containing products. T…
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EU Council implements updated Iran human rights sanctions designations under the 2011 restrictive measures framework
On 24 July 2026, the EU Council issued a Council Implementing Decision updating designations under the Iran human rights sanctions regime established in 2011. The decision adds or modifies listings of persons and entitie…
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EU Council implements updated Iran sanctions designations under Regulation 359/2011 effective 24 July 2026
On 24 July 2026, the EU Council issued an implementing regulation updating restrictive measures against specified persons, entities, and bodies under the Iran human rights sanctions framework. The regulation takes effect…
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EU Council adds new designations under Iran human rights sanctions regime effective 24 July 2026
On 24 July 2026, the EU Council issued an Implementing Decision updating designations under the Iran human rights restrictive measures framework. The decision adds or amends listings of persons and entities subject to as…
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EU Council adds new designations under Ukraine sanctions regime via Implementing Regulation of 23 July 2026
The EU Council adopted Implementing Regulation (EU) 2026/1843 on 23 July 2026, implementing the Ukraine territorial integrity sanctions framework. The regulation adds or amends designations, triggering immediate asset-fr…
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