The Blacklist: NDAA Section 889 Prohibited Entities

The following entities are explicitly designated as “covered telecommunications equipment or services” under the National Defense Authorization Act for Fiscal Year 2019, Section 889 (P.L. 115-232).

Section 889(a)(1)(A) prohibits federal agencies from procuring equipment from these entities. Section 889(a)(1)(B) prohibits federal contractors from using equipment from these entities in any of their operations — regardless of whether the project is federally funded.

Primary Prohibited Entities

Entity	Country	Sector	Legislation	Known Subsidiaries
Hangzhou Hikvision Digital Technology	China	Video Surveillance	NDAA Sec 889, FCC Covered List	EZVIZ, HiLook
Zhejiang Dahua Technology	China	Video Surveillance	NDAA Sec 889, FCC Covered List	Imou, Lorex (legacy)
Huawei Technologies (incl. HiSilicon)	China	Telecom / Chips	NDAA Sec 889, FCC Covered List	HiSilicon
ZTE Corporation	China	Telecommunications	NDAA Sec 889, FCC Covered List	—
Hytera Communications	China	Two-Way Radio / Body Cameras	NDAA Sec 889, FCC Covered List	—
DJI (Da-Jiang Innovations)	China	UAV / Drones	ASDA, FCC Covered List	—
Autel Robotics	China	UAV / Drones	FCC Covered List	—

The OEM Risk: What the Label Doesn’t Show

The brand on a device often does not reflect the actual manufacturer. Hikvision and Dahua produce hardware sold under dozens of Western brand names. A device with a MAC address beginning with 5C:34:5B, 64:DB:8B, 80:F5:AE, or C8:A7:02 originates from Hikvision hardware regardless of the outer label.

Use the MAC Lookup Tool for immediate OUI-based verification. See Grey Market Risks for the full analysis of OEM rebrands and high-risk brands.

The “Taint” Rule (Section 889(a)(1)(B))

This provision is widely misunderstood. A federal contractor does not need to be using banned equipment on the specific government project to be in violation. If banned cameras are installed anywhere in the contractor’s own facilities — in their lobby, warehouse, or parking lot — the contractor is in violation and cannot hold a federal contract.

This clause forces the entire defense industrial base to audit and replace banned equipment from all facilities, not just project sites.