FAR 52.204-25 is the federal contract clause that implements NDAA 2019 Section 889. In plain terms: it prohibits federal agencies and their contractors from buying or using covered telecommunications and video-surveillance equipment from Hikvision, Dahua, Huawei, ZTE, and Hytera — including their subsidiaries, affiliates, and OEM rebrands. For security-equipment buyers, that means any camera, recorder, or access system you specify must be free of these brands and their covered components, verified down to the specific model.
The clause has real teeth: it reaches equipment used anywhere in your operations, not just on the contract at hand, and it flows down to subcontractors. Below is what the rule covers, how it differs from TAA, and which brands are safe to specify.
What FAR 52.204-25 actually prohibits
FAR 52.204-25 carries the operative language of NDAA 2019 Section 889 into your contract terms. Two parts matter for security buyers:
- Part A bars an agency from procuring equipment or services that use covered telecommunications or video-surveillance equipment.
- Part B bars the government from contracting with any entity that uses covered equipment or services as a substantial or essential component of any system — even on work unrelated to the federal contract.
"Covered" equipment means products from the named entities — Hikvision, Dahua, Huawei, ZTE, and Hytera — plus their subsidiaries, affiliates, and the many OEM rebrands that ship the same hardware under a different label. Video-surveillance and telecommunications equipment from these companies is named explicitly in the statute, which is why cameras and recorders draw so much scrutiny. The clause flows down through subcontractors and is reinforced by the FAR 52.204-26 representation, where you certify whether you use covered gear.
Why the banned brands are non-negotiable
Brands such as Uniview (UNV), Lorex, EZVIZ, Annke, LTS, Alibi, LaView, ICRealtime, Q-See, and Reolink are widely sold and inexpensive, but many are Chinese-origin or rebrands tied to covered hardware. For federal use these are not a discount option — equipment that falls under FAR 52.204-25 must be removed and replaced, not merely documented. If covered cameras are already on a facility, that is a rip-and-replace project, not a paperwork fix. The same caution applies before you certify: certifying compliance while covered gear is in service is the exposure FAR 52.204-26 is designed to surface.
What "compliant" looks like under the clause
A camera is acceptable when it is not made by a covered entity and contains no covered components (for example, no Huawei/HiSilicon system-on-chip). Compliance is determined per SKU and per bill of materials — a single brand can offer both compliant and non-compliant models, so the specific model on the quote has to be verified, not the brand name alone.
Lines we design with that offer federally appropriate, 889-compliant options include Axis Communications, Hanwha Vision (Wisenet), i-PRO, Bosch, Avigilon and Pelco (Motorola Solutions), Genetec, Milestone (XProtect), Digital Watchdog, VIVOTEK, ACTi, MOBOTIX, Speco Technologies, Salient Systems, exacqVision, and Verkada. For access control, HID Global, Mercury Security, LenelS2 (OnGuard), Software House (C-CURE 9000 / iSTAR), Brivo, and STid carry compliant lines. None of these are 889 covered entities. (Ubiquiti is US-based and not a covered party, but its UniFi Protect line is a prosumer/IT product rather than a federally marketed surveillance line — verify the specific model before relying on it.)
TAA is a separate test
FAR 52.204-25 is about who made it and what's inside it. The Trade Agreements Act (19 U.S.C. 2501) is a separate country-of-origin rule: the product must be made or substantially transformed in the US or a TAA-designated country. China, Russia, and India are not designated. A camera can be NDAA-compliant yet fail TAA if it's assembled in a non-designated country — and vice versa. Compliant brands span Sweden (Axis), Germany (Bosch, MOBOTIX), Canada/US (Genetec, Avigilon, Pelco), Denmark (Milestone), Japan/US (i-PRO), South Korea with US-assembled lines (Hanwha), Taiwan (VIVOTEK, ACTi), and the US (Digital Watchdog, Speco, Verkada, HID). TAA status still depends on the specific model's manufacturing origin, so both tests have to clear on the exact SKU you buy.
Where Uniqcli fits
Uniqcli Security is a TAA and NDAA Section 889-compliant physical-security integrator. We design, integrate, and manage camera, access-control, intrusion, and monitoring systems and sell direct — vendor-neutral, so we source the right compliant line for the mission rather than pushing one brand. We confirm 889 and TAA posture at the SKU level and hand contracting and audit teams the documentation they need to support a clean FAR 52.204-25 and 52.204-26 representation.
If you're specifying a new system or unsure whether equipment already installed is covered, request a quote or schedule a compliance assessment with Uniqcli. We'll verify each model against both the 889 and TAA tests and deliver a build that stands up to contracting review — with no payment required up front.
