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Seven Things You Need to Know about USAID Geographic Codes: For Acquisition

Guest BloggerTips & Guidance
Antique globe showing North America
Oct 4, 2022

Olga Wall is the President of Avallon LLC, a woman-owned small business.

Disclaimer: This article was submitted to WorkwithUSAID.org as a guest blog post. The views expressed by WorkwithUSAID.org guest blog contributors do not necessarily reflect the views of the United States Agency for International Development or the United States Government. 

Who can sell goods and/or services to USAID and USAID contractors and grantees? This question has many different answers depending on the types, conditions, and terms of each opportunity and whether this opportunity is a direct USAID procurement or whether it is an opportunity to partner with or provide services or goods to a USAID contractor or recipient.

Before you decide to spend time and money on preparing a bid, you must learn about “geographic code eligibility.” This blog focuses on geographic code information for contracts; for information about how geographic code applies to assistance agreements, please see this earlier blog post

1. What is a “geographic code”?

Each USAID implementation instrument specifies a USAID three-digit geographic code. Each code represents those countries where goods must be located at the time of purchase and where companies that sell those goods or services must be legally organized and operational.

Main code 937 includes the United States, the recipient country, and developing countries. Current “developing countries” are listed here: List of Developing Countries ADS 310.

Code 935 means free world and includes all countries except prohibited sources countries. There are no prohibited source countries at the moment.

Code 110 means newly independent states of the former Soviet Union (an outdated description) and any developing country (see above).

2. What does geographic code mean?

Each geographic code governs “source” (of goods) and “nationality” (of supplier/company).

See 22 CFR 228 for complete definitions.

Source means the country from which a commodity is shipped to the cooperating/recipient country or the cooperating/recipient country itself if the commodity is located therein at the time of the purchase, irrespective of the place of manufacture or production, unless it is a prohibited source country.

Nationality refers to the place of legal organization, ownership, citizenship, or lawful permanent residence of companies which are supplying the commodities and services.

3. When and how does a geographic code apply under USAID contracts?

If your company wishes to submit an offer (bid or proposal) in response to a USAID Request for Proposals (RFP) or Request for Quotations (RFQ), your company must comply with the geographic code for “nationality.” If you are selling goods, in addition to your company’s compliance with “nationality,” your goods must comply with the geographic code for “source” restrictions.

If your company wants to sell its services or goods to a USAID prime contractor (as a subcontractor or a vendor), you must comply with the geographic code in the same way as above.

USAID Direct Contracts (Acquisition): All USAID RFPs or RFQs include the applicable geographic code. This code applies to all contractors who are planning on submitting an offer or quotation to USAID in response to that RFP or RFQ.

Subcontractors & Suppliers under Prime USAID Contracts: All subcontractors providing services or goods in the performance of the prime contract and all suppliers (not subcontractors) which provide auxiliary services or goods to the Prime contractor (internet providers, supplies, travel, hotels, generators, furniture, information technology [IT] equipment) must comply with the stated geographic code.

Grants under Prime USAID Contracts (GUCs): Grantees receiving grants under USAID contracts are NOT subject to the geographic code restrictions in the prime contract.

Responsibility to verify: USAID contracting officers are required to check geographic code eligibility of each prime contractor as part of the overall responsibility determination under direct competitive and noncompetitive acquisition actions. USAID prime contractors are responsible for verifying eligibility of their subcontractors and vendors as part of their procurement procedures.

4. What are the exceptions to the application of geographic code?

  • Foreign government-controlled organizations
  • Construction procurement with foreign-owned local firms
  • Miscellaneous transactions

5. Does geographic code’s “nationality” apply to employees/consultants of USAID contractors?

No, geographic code does not apply to the employees of contractors nor individual consultants.

6. Are there any special rules which apply to commodities and services procured by USAID contractors?

Yes, the following items have special approval requirements and rules:

  • Pharmaceuticals
  • Agricultural commodities and products
  • Pesticides
  • Used equipment
  • Fertilizers
  • Motor vehicles

The following commodities and services may never be financed with USAID contract (or subcontract) funds:

  • Military equipment
  • Surveillance equipment
  • Commodities and services for support of police and other law enforcement activities
  • Abortion equipment and services
  • Luxury goods
  • Gambling equipment
  • Weather modification equipment
  • Certain information technology (IT) services/equipment (Kaspersky Lab, Huawei)

7. Can a waiver of geographic code be obtained?

USAID, generally, does not grant waivers of geographic code for prime contractors bidding on direct USAID contracts. USAID may grant a waiver to a prime contractor to purchase goods or services from a company which does not meet the geographic code.

Any individual transaction not exceeding $25,000 (excluding prohibited countries or goods) does not require a waiver and is authorized for all.

Additional resources: