Federal agencies, government contractors, and organizations supporting federal projects need to pay close attention to the technology they purchase and deploy. Section 889 compliant IT equipment is an important consideration when procuring networking, telecommunications, video surveillance, and related technology for covered federal activities.
Section 889 of the National Defense Authorization Act for Fiscal Year 2019 established restrictions involving certain telecommunications and video surveillance equipment and services. For procurement teams, compliance is not simply about choosing a familiar brand. Buyers should identify the exact product, manufacturer, supplier, and applicable federal requirements before placing an order.
This guide explains Section 889, the types of technology that may be affected, how contractors and government buyers can evaluate products, and what information to request from an IT supplier.
Important: This article provides general procurement information and is not legal advice. Federal buyers and contractors should review the current FAR, solicitation, contract clauses, and applicable federal guidance for their specific procurement.
Table of Contents
What Is Section 889?
Section 889 establishes federal restrictions concerning certain telecommunications and video surveillance equipment and services associated with specified covered entities.
The requirements are commonly divided into two major areas:
Section 889(a)(1)(A) restricts the federal government from procuring or obtaining certain covered telecommunications and video surveillance equipment or services.
Section 889(a)(1)(B) addresses certain federal contracts with entities that use covered telecommunications equipment or services in their own systems or operations.
The practical procurement implications depend on the specific transaction, contract, equipment, service, and applicable Federal Acquisition Regulation (FAR) provisions.
For this reason, government purchasing teams should evaluate the actual requirements that apply to each acquisition rather than treating Section 889 as a simple product-label requirement.
Why Section 889 Matters for IT Procurement
Modern technology systems can contain products from multiple manufacturers and suppliers. A single government IT project might involve switches, routers, wireless equipment, cameras, communication systems, and other network infrastructure.
That makes product identification important.
A procurement team should know exactly what it is buying and from whom. Manufacturer information, model numbers, part numbers, supplier documentation, and applicable representations can all contribute to a more complete procurement record.
When purchasing Section 889 compliant IT equipment, buyers should therefore consider both the equipment and the procurement requirements that apply to the contractor or supplier.
What Technology Can Be Affected by Section 889?
Section 889 is particularly relevant to certain telecommunications and video surveillance equipment and services.
Depending on the applicable requirements, procurement teams may need to evaluate products such as:
Networking Equipment
Potentially relevant technology can include:
Network switches
Routers
Wireless networking equipment
Telecommunications hardware
Network infrastructure components
Video Surveillance Equipment
Examples can include:
Security cameras
Video surveillance systems
Network video recorders
Surveillance-related networking equipment
Communications Equipment
Certain communications equipment and services may also fall within the scope of the applicable restrictions.
However, buyers should not assume that every product within these broad categories is automatically prohibited. The statutory and regulatory definitions and the circumstances of the acquisition determine what restrictions apply.
What Does Section 889 Compliant IT Equipment Mean?
The term Section 889 compliant IT equipment is commonly used to describe technology that has been evaluated against applicable Section 889 restrictions and is not prohibited under those requirements.
However, compliance should be supported by specific product and procurement information.
For example, a government buyer may want to document:
Manufacturer name
Exact model number
Manufacturer part number
Product category
Supplier or distributor
Applicable compliance documentation
Relevant representations
Contract-specific requirements
Other required procurement information
A product page saying “government compliant” should not automatically replace the buyer’s own procurement review.
Companies Identified Under Section 889
Section 889 identifies specific covered entities in connection with its restrictions. The statutory and regulatory framework includes entities such as:
Huawei Technologies Company
ZTE Corporation
Hytera Communications Corporation
Hangzhou Hikvision Digital Technology Company
Dahua Technology Company
The applicable rules can also address subsidiaries, affiliates, and other entities as specified by law and regulation.
Because federal requirements and government resources can change, procurement professionals should use current official federal sources when performing a compliance review rather than relying on an old list or an outdated supplier statement.
How to Verify Section 889 Compliant IT Equipment
A documented verification process can help government buyers and contractors evaluate technology before purchase.
1. Identify the Exact Product
Start with the specific product rather than a general category.
Record:
Manufacturer
Product name
Model number
Manufacturer part number
Product type
Supplier
Quantity
For example, “network switch” is not enough information for a detailed procurement review. The exact manufacturer and model provide much more useful information.
2. Review the Applicable Federal Requirement
Determine which Section 889 requirement applies to the transaction.
Review the applicable:
FAR provisions
FAR clauses
Solicitation
Contract
Agency requirements
Procurement instructions
Different acquisitions can have different requirements, so the actual procurement documents should be reviewed.
3. Request Supplier Documentation
Ask the supplier for relevant compliance information when appropriate.
Depending on the procurement, documentation may include:
Manufacturer information
Supplier attestation
Product compliance statement
Applicable representation
Product specifications
Country-of-origin information when separately required
Contract-specific documentation
4. Check Current Government Resources
Government procurement teams should verify information against current federal resources.
The Federal Acquisition Regulation provides the primary regulatory framework for federal acquisitions, while SAM.gov provides important federal registration and entity information.
5. Maintain the Procurement Record
Keep the documentation used to evaluate the purchase.
A procurement file may include:
Product quotation
Manufacturer information
Product model
Supplier information
Compliance documentation
Applicable representations
Contract or solicitation requirements
Purchase order
This creates a clearer record of the procurement process.
Section 889 and FAR 52.204-24
Federal contractors may encounter FAR 52.204-24, Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment.
The provision concerns representations relating to covered telecommunications and video surveillance equipment or services.
Contractors should review the current version of the applicable FAR provision and the specific solicitation or contract rather than relying on an old representation from another project.
When a procurement involves Section 889 compliant IT equipment, the contractor should make sure its representations correspond to the requirements actually included in the applicable federal acquisition.
Section 889 and FAR 52.204-25
FAR 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment, is another important federal acquisition provision concerning Section 889.
The exact obligations depend on the applicable contract and FAR requirements.
Contractors should therefore review the clause included in their contract and obtain clarification from the appropriate contracting personnel when the requirements are unclear.
Section 889 and TAA Compliance Are Different
Section 889 and the Trade Agreements Act (TAA) are separate federal procurement requirements.
This distinction is important because a product can potentially need to satisfy multiple procurement requirements at the same time.
TAA generally concerns applicable trade-agreement and country-of-origin requirements for covered acquisitions. Section 889 addresses specified telecommunications and video surveillance equipment and services and covered entities.
Therefore, government buyers should separately evaluate:
Section 889 requirements
TAA requirements
Country-of-origin requirements
Buy American requirements where applicable
Agency-specific requirements
Contract-specific clauses
Meeting one procurement requirement does not automatically establish compliance with another.
Why Country of Origin Is Not Enough
A common misunderstanding is that the country where a product was manufactured or assembled automatically determines Section 889 compliance.
That is not a sufficient compliance review.
Section 889 focuses on covered equipment, services, and entities under the applicable federal requirements. Therefore, buyers should identify the actual manufacturer and product rather than using country of origin as the only screening method.
Country-of-origin requirements should be evaluated separately when TAA or another applicable federal purchasing rule applies.
Questions to Ask an IT Supplier
Before ordering technology for a federal project, contractors and government purchasing teams can ask suppliers specific questions.
What is the exact manufacturer and part number?
This establishes precisely which product is being quoted.
Can you provide Section 889 compliance documentation?
Request appropriate supporting information for the procurement when available.
Who is the manufacturer?
Manufacturer identification can be particularly important for telecommunications and surveillance products.
Can you provide applicable product specifications?
Technical documentation helps buyers verify that the quoted product matches the project requirements.
Can you provide country-of-origin information?
This can be useful when evaluating TAA or other country-of-origin requirements separately.
Is the product available through an established distribution channel?
Supply-chain and product traceability information can help procurement teams maintain better records.
Can you quote the complete bill of materials?
For larger IT projects, obtaining one organized quotation for the required equipment can simplify purchasing and documentation.
Section 889 Procurement Checklist
A standardized checklist can help organizations evaluate government IT purchases consistently.
Procurement Item
Information to Verify
Manufacturer
Exact manufacturer name
Part number
Exact manufacturer part number
Product type
Networking, surveillance, communications, etc.
Supplier
Selling supplier or distributor
Section 889 review
Applicable requirement
Compliance documentation
Available supporting information
FAR requirement
Applicable provision or clause
TAA review
Separate country-of-origin evaluation
Contract requirement
Solicitation or contract requirements
Procurement record
Quote and supporting documents
Using a checklist can be especially useful when a government project includes multiple manufacturers and dozens or hundreds of individual IT products.
Section 889 Compliant IT Equipment for Networking Projects
Large network installations can contain many individual products.
A government networking project may include:
Ethernet switches
Routers
Wireless access points
Firewalls
Network controllers
Fiber-optic equipment
Structured cabling
Network accessories
Monitoring equipment
Each product should be evaluated according to the requirements applicable to the procurement.
For larger projects, a product-by-product compliance worksheet can help procurement teams keep manufacturer information and supporting documentation organized.
Section 889 Compliance for Video Surveillance
Video surveillance requires particular attention because Section 889 specifically addresses certain telecommunications and video surveillance equipment and services.
For a surveillance project, buyers may document:
Camera manufacturer
Camera model
Recorder manufacturer
Recorder model
Network equipment
Supplier
Compliance documentation
Applicable contract requirements
When supporting documentation is required, obtain it before the purchase and installation whenever possible.
Common Section 889 Procurement Mistakes
Checking Only the Product Brand
A proper review should identify the exact manufacturer and model rather than relying only on the name displayed on a reseller’s website.
Treating TAA and Section 889 as the Same Requirement
They are separate federal procurement requirements and should be evaluated independently.
Using Outdated Information
Federal procurement rules and official guidance can change. Always verify the current requirements before making a compliance determination.
Ignoring Contractor-Level Requirements
Depending on the applicable FAR clauses and contract, Section 889 considerations may extend beyond the specific products supplied to the government.
Failing to Keep Documentation
A procurement decision is easier to review when the organization retains the product information and supporting documents used during the evaluation.
How to Build a Section 889 IT Procurement Process
Organizations purchasing technology regularly can establish a repeatable process.
A basic workflow can be:
Identify → Verify → Document → Purchase → Retain Records
First, identify the exact equipment and manufacturer.
Next, verify the applicable Section 889 and contract requirements.
Then, document supplier representations and other supporting information.
After completing the procurement review, purchase the specified equipment.
Finally, retain the documentation according to the organization’s applicable recordkeeping requirements.
This approach can make future purchases more consistent and reduce the risk of relying on incomplete product information.
How OSSSINC Supports Government IT Purchasing
One Stop Shop Solutions Inc provides IT, networking, printing, office, industrial, and facility products for business and government purchasing.
Government buyers can provide the exact manufacturer, part number, quantity, delivery requirements, and applicable procurement specifications when requesting a quote.
For products where applicable documentation is available, OSSSINC can provide supplier information and supporting product documentation for procurement review.
For broader purchasing requirements, buyers can also explore the OSSSINC full catalog.
Frequently Asked Questions About Section 889 Compliant IT Equipment
What is Section 889 compliant IT equipment?
Section 889 compliant IT equipment is technology that has been evaluated against the applicable Section 889 restrictions and is not prohibited under those requirements. Buyers should verify the exact manufacturer, model, and applicable federal procurement requirements.
What does Section 889 cover?
Section 889 establishes federal restrictions involving certain telecommunications and video surveillance equipment and services associated with specified covered entities. The exact scope depends on the applicable statutory and regulatory requirements.
Does Section 889 apply to government contractors?
Yes, certain Section 889 requirements apply to federal contractors. Contractors should review the FAR provisions and clauses included in their specific solicitations and contracts.
Does Section 889 apply to network switches and routers?
Certain telecommunications equipment can fall within the scope of Section 889. Buyers should evaluate the exact product, manufacturer, applicable definitions, and procurement requirements rather than assuming that every networking product is automatically prohibited.
Does Section 889 apply to security cameras?
Section 889 specifically addresses certain video surveillance equipment and services. Government buyers should verify the exact manufacturer, model, supplier, and applicable procurement requirements before purchasing surveillance equipment.
Is Section 889 the same as TAA?
No. Section 889 and TAA are separate federal procurement requirements. A product may need to satisfy both when both requirements apply to the acquisition.
Does country of origin determine Section 889 compliance?
No. Country of origin alone does not establish Section 889 compliance. Buyers should evaluate the applicable equipment, services, entities, and federal procurement requirements.
How can I verify Section 889 compliant IT equipment?
Identify the exact manufacturer and part number, review the applicable FAR and contract requirements, request relevant supplier documentation, consult current federal procurement resources, and retain the supporting information in the procurement record.
What should I provide when requesting a government IT quote?
Provide the manufacturer, exact part number, quantity, delivery requirements, contract or project information, and applicable compliance requirements. A complete bill of materials can help the supplier prepare a more accurate quotation.
Can OSSSINC provide government IT procurement support?
One Stop Shop Solutions Inc provides IT, networking, printing, office, industrial, and facility products for business and government buyers. Buyers can provide their product specifications and quantities when requesting a quotation.
Final Takeaway
Understanding Section 889 compliant IT equipment is an important part of federal technology procurement.
Government buyers and contractors should identify the exact products being purchased, review the applicable FAR and contract requirements, verify manufacturer and supplier information, and retain documentation supporting the procurement review.
Section 889 should also be evaluated separately from TAA, country-of-origin rules, and other federal purchasing requirements that may apply to the same acquisition.
