On June 24, 2026, the General Services Administration (“GSA”) issued a Request for Information (“RFI”) seeking input on two proposals for promoting the purchase of American-made products on GSA Advantage, an online shopping and ordering system, which GSA advertises as providing access to thousands of contractors with millions of products and services.  Comments in response to the RFI are due by July 24, 2026.

Citing Executive Order 14392, which Covington previously covered in a client alert, the RFI reflects a broader push by the Trump administration to increase focus on domestic sourcing, including in federal procurement, and to ensure that “Made in America” representations are accurate.[1] As part of that effort, the Small Business Administration and GSA recently de-listed 22 product offerings from the GSA Advantage platform based on false Made in America representations, and President Trump declared that all federal agencies must buy American. Consistent with this policy direction, the RFI seeks input on ways to “make it easier for federal agencies to buy American-made products.”  This blog post focuses on the mechanics of GSA’s two proposals, the information sought by GSA in the RFI, and considerations for contractors.

I. The Voluntary Representation Approach

This approach contemplates that GSA Advantage would permit offerors to “voluntarily represent that their products meet the component test and qualify as made in America.”  At a high-level, the Buy American Act (“BAA”) component test, set forth in FAR Part 25.101(a)(2)(i), requires the cost of wholly or predominantly non-iron and steel domestic components to exceed 65% of the cost of all components, which increases over time to 75% by 2029.[2] Covington previously covered this increase here and here.

Compliant products would then receive an icon identifying them as qualifying Made in America products and would be sorted to appear on GSA Advantage at the top of search results.  The icon and sorting would permit federal agencies to quickly and easily procure products that align with the Administration’s Made in America approach.  If a buyer does not select one of these qualifying products, GSA will request a survey to understand the reasoning behind the purchase decision.

The RFI seeks input on expected compliance costs and downstream pricing changes, in addition to whether contractors and vendors would (1) change manufacturing processes to ensure products meet the BAA component test; (2) share compliant BAA component information directly with the government; (3) guarantee that only U.S. items will be shipped to government buyers; and (4) receive component information from original equipment manufacturers (“OEMs”).

II. The Special Item Number Approach

Under this approach, GSA would create a new Special Item Number (“SIN”) for products that meet the BAA component test.  The new SIN would be limited to select product categories, and would be exclusive to OEMs.  Contemplated product categories include batteries, cleaning equipment, hardware and tools, building materials, and office furniture.  Moreover, GSA “would likely restrict OEMs that offer a product under the [new] SIN from offering that same product under any other SIN.”

The RFI seeks input on the kinds of industries that would be best suited for a new SIN, in addition to expected compliance costs and downstream pricing changes, among other topics.

III. Initial Takeaways

This latest action is a clear signal that the Administration remains focused on promoting domestic procurement and introducing changes to the procurement system to accomplish that objective.  Contractors should consider submitting feedback to inform GSA’s path forward, and monitor GSA Advantage for changes in the platform. 

At the same time, Executive Order 14392 reinforces that any changes to GSA Advantage to promote domestic procurement will occur in a broader enforcement environment where GSA is required to, among other things, “periodically review and verify any Buy American Act, Country of Origin USA, or similar American-origin claims for products . . . .” (internal quotations omitted).  In light of the increased focus by the Administration on this area, if GSA moves forward with one or both of these approaches, contractors should carefully evaluate the applicable eligibility criteria before representing that a product qualifies as “Made in America.”

[1] Proposed amendments to FAR Part 7 issued last month also reflect an increased emphasis on domestic sourcing.  For example, proposed FAR 7.104(a) would encourage acquisition planning to consider the “capabilities of domestic sources,” while proposed FAR 7.104(b)(7) would instruct requirements and logistics personnel to “consider ways to promote participation by domestic sources to the maximum extent practicable . . . .” 

[2] The domestic component test is currently waived for commercial off-the-shelf items.