What Section 889 Actually Means for Electronics Buyers

Published April 2026. Plain-language explainer for procurement officers, cardholder buyers, and small-business owners navigating federal purchase compliance.

If you buy electronics for a federal agency, a state agency receiving federal pass-through funds, or a commercial organization that contracts with the federal government, you have probably come across the phrase "Section 889 compliant" on supplier documentation. It is one of the most consistent questions procurement officers ask when evaluating new vendors — and one of the easiest to answer incorrectly.

This guide explains what Section 889 actually prohibits, who is bound by it, what a "Section 889 representation" really means, and how to verify that an electronics supplier can legitimately claim it.

What Section 889 actually is

Section 889 refers to a specific section of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 (Public Law 115-232). It has two operative parts:

  • Section 889(a)(1)(A) prohibits executive branch agencies from procuring certain telecommunications and video surveillance equipment or services produced by specific Chinese companies. This took effect August 13, 2019.
  • Section 889(a)(1)(B) prohibits those same agencies from contracting with entities that use such equipment as a substantial or essential component of any system, regardless of whether that equipment is used in the performance of the government contract itself. This took effect August 13, 2020.

Part A is about what you sell. Part B is about what you use to run your business.

Who it applies to

Section 889 directly binds executive branch federal agencies and their contractors. In practice the reach is broader — any vendor seeking to sell to a federal agency, including state, local, or tribal entities administering federal pass-through funds, is typically required to certify compliance before award. Commercial buyers with federal contract obligations often flow the requirement down to their own supply chain as well.

If your procurement is funded with federal dollars at any level, expect Section 889 representations to be required.

What equipment is actually prohibited

The statute names five companies whose telecommunications and video surveillance products are explicitly restricted, along with their subsidiaries and affiliates:

  • Huawei Technologies Company — telecommunications equipment and services
  • ZTE Corporation — telecommunications equipment and services
  • Hytera Communications Corporation — video surveillance and telecommunications
  • Hangzhou Hikvision Digital Technology Company — video surveillance
  • Dahua Technology Company — video surveillance

The key legal phrase is "covered telecommunications equipment or services" — this is the shorthand FAR uses for anything produced by any of these five companies or their corporate affiliates. If a product's bill of materials includes components from any of these manufacturers, the product may itself be considered "covered" even if it is sold under a different brand.

The FAR clauses that actually enforce it

Section 889 is implemented through three specific clauses in the Federal Acquisition Regulation (FAR):

  • FAR 52.204-24 — the Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment. This is the form a supplier signs. It has two parts — Part A (do you provide covered equipment?) and Part B (do you use covered equipment?). Each has a "Does" / "Does not" checkbox.
  • FAR 52.204-25 — the Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment. This is the actual restriction that flows down through federal contracts. It also imposes a one-business-day reporting requirement if a contractor discovers covered equipment in their supply chain during contract performance.
  • FAR 52.204-26 — a related representation clause addressing similar prohibitions for solicitation phase.

When you see a supplier claim "we hold a current Section 889 representation," that is specifically a reference to FAR 52.204-24 — a signed form with both Part A and Part B marked "Does not."

What a "Section 889 representation" is and is not

Section 889 compliance does not come with a third-party certification number you can look up in a database. There is no federal agency that issues "889 certificates." The representation is a self-attestation made under FAR 52.204-24, signed by an authorized representative of the supplier, with the full legal consequences of a signed federal representation.

That is a stronger statement than it sounds. A false Section 889 representation exposes the signer to federal False Claims Act liability, potential debarment, and — in cases involving willful misrepresentation — criminal penalties. The representation is binding for twelve months from the signature date and must be re-executed on renewal.

When verifying a supplier's claim, ask for:

  • A copy of the signed FAR 52.204-24 representation form
  • The signature date (representations expire after twelve months)
  • Confirmation of both Part A and Part B status ("Does not" / "Does not")
  • The legal entity name signing the representation (should match the vendor's SAM.gov entity if applicable)

What it does NOT cover

Section 889 is narrowly targeted at the five named companies and their products. It does not:

  • Require that all products be manufactured in the United States — that is a separate regulation (the Trade Agreements Act, TAA, with a different list of covered/prohibited countries).
  • Require Buy American compliance — again, separate rules.
  • Prohibit all Chinese-manufactured products — only those from the five named companies and their affiliates.
  • Apply to purchases below certain agency-specific micro-purchase thresholds in many cases, though buyer internal policy may still require it.

Buyers who need TAA compliance or Buy American compliance in addition to Section 889 should verify those separately with the supplier, typically on a per-SKU basis (country of manufacture).

Red flags when evaluating a supplier's 889 claim

  • Vague language like "we are 889-compliant" without mentioning FAR 52.204-24 or offering a signed representation on request. The representation is a specific form; compliance language should reference it.
  • Stale representations. The form is only valid for twelve months. Ask when it was last signed.
  • Mismatched entity names between the representation and the business the buyer is actually purchasing from. The legal signer should match the seller on the invoice.
  • Refusal to provide a signed copy on reasonable request. A supplier who has actually signed the representation should be able to email a copy within a business day.
  • Conflating 889 with TAA. These are different rules. A supplier claiming "889 and TAA compliant" across their entire catalog is either overclaiming (TAA is per-SKU) or hasn't read both regulations carefully.

How Stokvane handles Section 889

Stokvane is operated by TyTred Services LLC DBA Stokvane. The legal entity holds a current FAR 52.204-24 representation with both Part A ("Does not provide") and Part B ("Does not use") marked, signed April 2026, valid twelve months.

All Section 889 covered telecommunications products — Huawei, ZTE, Hytera, Hikvision, Dahua, and their affiliates — are explicitly excluded from our catalog per Part A of the signed representation.

Federal contracting officers and cardholder buyers who need a fresh signed copy of our representation for a specific procurement can request one at support@stokvane.com with the subject line "Section 889 representation request". We respond within one business day.

For a full view of our government procurement posture — including SupplierGateway small-business verification, HUBZone designation, and NAICS codes served — visit our Government Buyers page.

Questions from a specific procurement office about a specific SKU or bundle? Email support@stokvane.com with the subject line "Government quote" and include the items, quantities, and any additional compliance attestations required (TAA, Berry Amendment, Buy American, etc.). We verify and quote.

Sources: FAR 52.204-24 — acquisition.gov, FAR 52.204-25 — acquisition.gov, DoD DPC Section 889 policy overview, John S. McCain NDAA FY2019 (Public Law 115-232).

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