◉ COMPLIANCE ◉

NDAA Section 889 Compliance

Full component segregation, transparent BOM, and restricted-party screening. Your supply chain partner for U.S. federal, defense, and critical infrastructure procurement.

[ OVERVIEW ]

Understanding NDAA Section 889

The John S. McCain National Defense Authorization Act (NDAA) for Fiscal Year 2019, Section 889, prohibits U.S. federal agencies, contractors, and grant recipients from procuring or using telecommunications and video surveillance equipment from specific Chinese manufacturers deemed a national security risk.

01

Part A — Federal Procurement Ban

Effective August 13, 2020: Prohibits the U.S. government from procuring or obtaining any equipment, system, or service that uses covered telecommunications equipment or services as a substantial or essential component of any system, or as critical technology as part of any system.

02

Part B — Contractor / Grant Ban

Effective August 13, 2020: Prohibits federal contractors and grant recipients from using covered equipment. Any entity receiving federal funds cannot use restricted equipment even in their internal operations. This extends the ban far beyond direct government procurement.

03

Covered Entities & Brands

The FAR (Federal Acquisition Regulation) identifies specific entities: Huawei Technologies, ZTE Corporation, Hytera Communications, Hikvision, Dahua Technology, and their subsidiaries and affiliates. Any product containing components from these entities is non-compliant.

04

Beyond the Brands — Component Level

Compliance is evaluated at the component level. A "compliant" camera that uses a restricted-brand image sensor, SoC, or firmware module is still non-compliant. Every IC, sensor, and firmware binary must be traceable to a non-restricted source.

[ COMPONENT TRACEABILITY ]

Restricted vs. NDAA-Compliant Components

EMS-SECURITY maintains a fully segregated supply chain. Our BOMs exclude all components from restricted entities.

▷ Restricted Entities

  • Hikvision / Hikvision OEM
  • Dahua Technology
  • Huawei / HiSilicon SoCs
  • ZTE Corporation
  • Hytera Communications
  • Uniview / Zhejiang Uniview
  • Any subsidiary or affiliate of above

▷ Our Compliant Supply Base

  • Ambarella SoCs (USA)
  • Novatek / iCatch (Taiwan)
  • Sony STARVIS sensors (Japan)
  • OmniVision sensors (USA)
  • ON Semiconductor (USA)
  • Realtek / MediaTek (Taiwan)
  • SigmaStar / Fullhan (non-restricted)
[ FULL BOM TRANSPARENCY ]

Sample Bill of Materials

Every order includes a BOM audit trail. Below is a representative BOM for our 8MP NDAA-compliant bullet camera (EMS-BC880A). Full traceability to manufacturer and country of origin.

▷ BOM: EMS-BC880A / 8MP IP Bullet Camera / Rev 2.3 / 2025-Q1
COMPONENTSPECIFICATIONSUPPLIERORIGIN
Image Sensor1/1.2" 8MP CMOSSony STARVIS IMX485Japan
Main SoCCV5S 4K AI ISPAmbarella CV5SUSA / Taiwan
DDR4 RAM4GB LPDDR4XSamsungSouth Korea
Flash Storage8GB eMMCKingstonTaiwan
Lens Assembly2.8-12mm F1.4Sunny OpticalChina (non-restricted)
IR LED Array850nm x 8OsramGermany
Ethernet PHY10/100/1000Realtek RTL8211Taiwan
PoE PD ControllerIEEE 802.3atTI TPS2375USA
Power ManagementMulti-rail PMICMPSUSA
HousingADC12 Die-cast AlEMS in-house toolingChina
Gaskets / SealsSilicone IP67ParkerUSA / CN
✓ ZERO restricted components verified✓ Independent 3rd-party audit available
[ COMPLIANCE PROCESS ]

How We Guarantee NDAA Compliance

Compliance is not a one-time check. It is embedded into every stage of our manufacturing process.

1

Supplier Vetting & Onboarding

Every component supplier undergoes restricted-party screening against the Consolidated Screening List (CSL), BIS Entity List, and SDN List. Only pre-approved vendors enter our AVL (Approved Vendor List).

2

BOM Architecture Review

Each new product BOM is reviewed by our compliance team before procurement. Every line item is checked against the restricted entities database. Alternative components are sourced where necessary.

3

Segregated Procurement & Warehousing

NDAA-compliant components are stored in physically separated inventory zones with distinct SKU prefixes. No cross-contamination between compliant and non-compliant production lines.

4

Lot-Level Traceability

Each production batch is assigned a unique lot code. Component reel IDs are scanned at SMT placement. The final unit serial number links back to every individual component lot. Full forward and backward traceability.

5

Firmware Integrity Verification

All firmware binaries are built from audited, non-restricted SDKs. No binary blobs from restricted entities. Checksums published with every release. Source available to qualified partners under NDA.

6

Shipment Documentation Package

Every order includes: (a) NDAA Compliance Certificate, (b) BOM with supplier/country-of-origin, (c) firmware checksum manifest, (d) 3rd-party audit report (optional, additional cost).

EMS-SECURITY NDAA Section 889 Compliance Statement

EMS-SECURITY certifies that all products designated as "NDAA-Compliant" in our catalog:

A signed compliance certificate is provided with every shipment. Third-party audit reports from accredited testing laboratories are available upon request.

Require NDAA-Compliant Documentation?

Tell us your compliance requirements. We provide full BOM disclosure, third-party audit reports, and compliance certificates with every order.

Request Compliance Package