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FAR ClauseCybersecurity

FAR 52.204-25Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment

Prohibits federal contractors from using or providing covered telecommunications equipment (Huawei, ZTE, Hytera, Hangzhou Hikvision, Dahua) or services that use such equipment in any government work.

When This Clause Applies

Required in all federal solicitations and contracts above the micro-purchase threshold. Section 889 Part B applies even when the equipment is not delivered to the government — covered equipment cannot be used 'as a substantial or essential component' anywhere in the contractor's operations.

What This Means for Contractors

Contractors must inventory their telecom and video surveillance equipment, eliminate covered equipment from operations, and represent annually that they do not use it. Subcontractors must also comply. Waivers exist but are narrowly granted by the DNI or agency CIO. Non-compliance can disqualify a firm from all federal contracts.

Common Pitfalls

  • 1Treating Section 889 Part A (sell-to-gov) and Part B (use-anywhere) as the same — Part B is much broader
  • 2Missing covered equipment in OEM components or branded resold products
  • 3Not flowing the prohibition to subcontractors and suppliers
  • 4Failing to update annual SAM.gov representation after equipment changes

Related Topics

FAR 52.204-25Section 889Huawei ZTE prohibitioncovered telecommunications equipmentSection 889 Part B

Need help complying with FAR 52.204-25?

Aliff helps GovCon firms map clause requirements to deliverables, build compliance evidence, and respond to CO inquiries with confidence.