VA FSS: US-Made Products
VA’s "US-Made" Product Update: What Pharma Manufacturers Need to Know
On Wednesday, the VA Office of Procurement, Acquisition, and Logistics (OPAL) sent an email update to pharmaceutical manufacturers about the government’s "Made in America" policies — along with potential actions required to mark products as "US-Made."
The Context
Currently, under Schedule 65 I B (Drugs, Pharmaceuticals & Hematology-Related Products), manufacturers must list a product’s country of origin. Products that are manufactured or substantially transformed in the U.S. (or a U.S.-designated country under FAR 52.225-5 Trade Agreements Act) are considered compliant. An additional disclosure is required if the country of origin is not the U.S. or a designated location.
What This Means for You
While the email was sent to all FSS contract holders, the examples and Request for Modification (RFM) guidance primarily focused on Commodities (Schedules 65 II A, 65 II C, 65 II F, 65 V A, and 65 VII). What this means for pharmaceutical manufacturers is still unclear — and the situation is evolving.
According to our VA contacts, this request is not yet mandatory. There's a possibility that, in the future, manufacturers may need to add "US-Made" to a product's description, but for now, we recommend holding off on RFM submissions. The key will be to ensure the "US-Made" label is added in a way that aligns with FSS requirements and can be effectively cataloged on NAC.
Stay tuned to the Woven blog for updates — we’ll keep you posted as things develop!
VA Email for Reference
VA Federal Supply Schedule
BACKGROUND: “Made in America” policies are designed to increase reliance on domestic supply chains and ultimately reduce the need to spend taxpayer dollars on foreign-made goods.
As FSS contracts are governed by the restrictions set forth in clause 52.225-5 Trade Agreements, only items that are either U.S.-made or are designated country end products (as defined in the clause) are permitted on schedule, and contractors are currently required to list the two-letter country of origin code on their proposed pricing spreadsheet for offers and product addition modifications, with products meeting the U.S.-made definition being listed as “US” for the country of origin.
ACTION REQUIRED: FSS contract holders supplying goods made in the US are encouraged to submit a Request for Modification (RFM) to add the term “US-Made” to their item descriptions. Ordering facilities must meet the requirements of the Made in America Act, and it is imperative that they be able to identify the items on FSS contracts that are US-Made. We have NAC-CM enhancements under way which will feed the two-letter country of origin code to the National Acquisition Center’s Contract Catalog Search Tool (CCST) for transparency and market research. Until that time, the text US-Made is to be followed exactly so that an additional product search criteria is available in the CCST as well as in GSA Advantage.
Please use the Administrative Change Request Package link below for the required RFM documents to submit these requests, and be sure to e-mail them to fss.help@va.gov, using the following subject line: RFM - Contract - Schedule - US-Made
RFM example: RFM - V797P-12345 – 65IIA – US-Made
Administrative Change Request Package
For further information on RFMs and the submission process, visit our RFP Process and Modifications Request Forms web pages. If you have any questions regarding this call for submissions, please speak with your assigned Contract Specialist.
Thank you!
Federal Supply Schedule Service
Published on March 4, 2025 by Jenny Bulkin