Federal Contracting
CAGE Codes for Foreign Entities Doing Business with the U.S. Government
Foreign companies can and do sell to the U.S. federal government, but the process involves additional steps compared to domestic entities. Obtaining the right identifier — whether a U.S. CAGE code, an NCAGE code, or both — is the first hurdle. This guide explains the registration pathway for international firms entering U.S. federal procurement.
The U.S. federal government purchases goods and services from foreign entities across a wide range of industries — from specialized technology components to professional services delivered outside U.S. borders. Foreign companies pursuing federal contracts face a registration process with some important differences from the domestic path, starting with the question of whether they need a U.S. CAGE code, an NCAGE code, or both.
Do Foreign Entities Need a SAM.gov Registration?
Any entity receiving a U.S. federal award — regardless of country of incorporation — must be registered in SAM.gov. This requirement applies to prime contractors and first-tier subcontractors receiving subawards above the reporting threshold. Foreign entities registering in SAM.gov go through largely the same process as domestic entities but with some important distinctions.
Foreign Entity Registration Requirements
Foreign entities registering in SAM.gov need:
- A physical address (no PO boxes; overseas addresses are accepted)
- A taxpayer identification number from your country of incorporation, or a U.S. EIN if your entity has U.S. tax obligations
- Your NCAGE code (if your country is a NATO member or uses the NATO codification system)
- A Unique Entity Identifier (UEI), assigned by SAM.gov during registration
- A U.S. financial institution account for EFT payments, or a waiver for payments via check or international wire
The NCAGE First Approach
If your company is in a NATO member nation, the recommended approach is to obtain your NCAGE code first through your country's National Codification Bureau, then use that code during SAM.gov registration. DLA will typically adopt the NCAGE number as the CAGE code, maintaining a consistent identifier across both systems. This streamlines logistics and invoicing for DoD contracts in particular.
Country Eligibility and Trade Agreements
The Trade Agreements Act (TAA) restricts the country of origin for certain government purchases. Foreign entities from TAA-designated countries (generally FTA partners and WTO Government Procurement Agreement signatories) can sell covered products to the U.S. government. Entities from non-TAA countries face restrictions on specific product categories, particularly technology hardware. Understanding TAA compliance is a prerequisite before investing in U.S. federal market entry.
Taxes and the Withholding Requirement
Foreign entities receiving payments from the U.S. government may be subject to withholding tax under IRS rules. CAGE code registration and SAM.gov activation do not automatically resolve withholding obligations. Foreign entities should consult a U.S. tax advisor and submit the appropriate IRS W-8 forms to avoid unexpected withholding from contract payments.
Agency-Specific Considerations
Different agencies have different attitudes toward foreign suppliers. The DoD has additional national security screening requirements under DFARS, including country-of-origin restrictions on electronic components (DFARS 252.225 series). NASA has technology transfer restrictions under the International Traffic in Arms Regulations (ITAR). Civilian agencies like GSA are generally more accessible to foreign entities.
After Registration
Once registered and assigned a CAGE code, foreign entities appear in the same SAM.gov search results as domestic firms. Contracting officers can decode your CAGE code on our CAGE Code Decoder to see your registration status and basic entity information. Your award history, once you start winning contracts, will appear on FedAtlas.com alongside all other U.S. federal awardees.
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