Even when doing business with state and local governments, companies still may find themselves subject to certain country of origin requirements, especially when federal funds are involved in local infrastructure projects. Federal grant programs administered through state and local governments are subject to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 C.F.R. Part 200), as well as agency-specific rules, regulations, and standard terms and conditions. This is in addition to any terms and conditions further imposed on grant recipients by state and local governments. To complicate things further, recipients may also be subject to new government-wide “Buy America” requirements implemented in the 2021 Infrastructure Investment and Jobs Act. In Part 4 of this 9-part series, the Sheppard Mullin Supply Chain Management Team discusses country of origin requirements under federal grant programs.
In this session, we will cover:
- New “Buy America” requirements under the 2021 Infrastructure Act;
- A sampling of other “Buy America” requirements relating to water management, broadband, and other utility services;
- Compliance tips and suggestions when performing under state or local contracts that incorporate federal country of origin requirements.
Country of Origin & Buy America 2024 Series
Third Thursday of the Month, 12:00-1:30pm ET
- January 18 – Buy American Act
- February 15 – Trade Agreements Act
- March 21 – Buy America Requirements under Federally-Funded Transportation Contracts and Programs
- April 18 – Country of Origin requirements under Federal Grant Programs
- May 16 – Customs and “Made in the U.S.A.” Labeling
- June 20 – DOD: The Berry Amendment
- July 18 – DOD: Specialty Metals Restrictions
- August 15 – “Buy America” Round-Up: Additional Country of Origin Requirements
- September 19 – Sanctions and other Prohibited Sources