The proposed update will remove the concept of "origin" all together and will simplify the concepts of "source" and "nationality".
In summary, under the new proposed regulations, if the award contains Geographic Code 000 (US), it will mean that commodities and services must be "available for purchase" and "can be serviced if warranted" in the US from/by US entities (legally registered and principle place of business in the US) and must have their origin in any non-restricted country (i.e. current code 935) and that commodities must be shipped to the cooperating country from US or shipped to a freeport from US before being shipped to the Cooperating Country.
The commodities no longer have to be "made/manufactured in the US" to be eligible.
The above rule will not apply to restricted goods (motor vehicles, ag inputs etc.) and is also above and beyond the blanket waiver for Local Procurement for Code 935 goods and services up to $5Mil per award signed in August of 2011.
Once finalized, we will post the final rule and explain the changes.