Federal contractors: Section 889 reaches the cameras you use, not only the ones you sell to the government

FAR 52.204-25 implements Section 889: contractors may not provide the government systems built on covered Huawei, ZTE, Hytera, Hikvision or Dahua equipment, agencies may not contract with entities that use it, and contractors must report covered equipment within one business day of finding it.

Source facts

FAR 52.204-25 implements Section 889 of the FY2019 National Defense Authorization Act. Covered equipment includes telecommunications equipment produced by Huawei or ZTE and, for public safety, security of government facilities, physical security surveillance of critical infrastructure and other national security purposes, video surveillance and telecommunications equipment produced by Hytera, Hikvision or Dahua, including their subsidiaries and affiliates.

The clause prohibits contractors from providing the government any equipment, system or service that uses covered equipment as a substantial or essential component or as critical technology, unless an exception or waiver applies. Since August 13, 2020, agencies are also barred from contracting with an entity that uses such equipment, regardless of whether the use is in performance of work under a federal contract.

A contractor that identifies covered equipment during performance must report within one business day, including supplier, brand and model, and provide further mitigation information within 10 business days; Department of Defense reports go to dibnet.dod.mil. The clause must be flowed down to subcontracts, and it defines a reasonable inquiry as one that excludes the need for an internal or third-party audit.

Applicability

Use this if your organization holds or bids federal contracts or subcontracts. The clause text shown is the November 2021 version on Acquisition.gov; confirm the clause and any agency-specific provisions in each solicitation.

DSE recommendation

DSE recommends that federal contractors inventory their own installed video and network equipment by actual manufacturer, not only the systems they deliver. Ask suppliers to identify the producer of rebranded or white-label cameras, recorders and radios, record the answers with model and serial numbers, and replace covered devices on a scheduled plan. Write the one-business-day reporting steps and the responsible contracts contact into the compliance procedure.

Verification

Reconcile the equipment inventory against purchase records and network discovery scans twice a year, and keep supplier producer declarations with the representation file. Run a mock report against the clause’s data list to confirm the required fields can be produced within a business day.

Official reference

Acquisition.gov — FAR 52.204-25, Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment. Reviewed October 18, 2026.