NDAA Section 889: What PIDS Buyers Need to Know in 2025

Federal procurement of perimeter intrusion detection systems in the United States continues to operate under the constraints of NDAA Section 889, a provision that prohibits executive agencies from procuring telecommunications and video surveillance equipment from five named Chinese manufacturers: Huawei, ZTE, Hytera, Hikvision, and Dahua.

For PIDS buyers in the federal space — and increasingly in the state, local, and critical infrastructure sectors that follow federal guidance — Section 889 shapes vendor selection, system design, and supply chain due diligence in ways that are not always straightforward.

What Section 889 Prohibits

The prohibition operates in two parts. Part A (effective August 2019) bars federal agencies from directly procuring covered equipment. Part B (effective August 2020) bars agencies from contracting with any entity that uses covered equipment, even if the equipment is unrelated to the government contract.

For perimeter security, the practical impact centres on video surveillance components. Many PIDS deployments integrate cameras for visual verification of intrusion alerts — thermal cameras to confirm a fence sensor hit, PTZ cameras slaved to radar tracks, or analytics-enabled cameras running classification algorithms at the edge. If any of these cameras contain Hikvision or Dahua components (including OEM boards sold under third-party brands), the system may fall outside federal compliance.

Where PIDS Buyers Get Caught

The most common compliance challenges for perimeter detection procurement:

OEM components. Several camera brands resell Hikvision or Dahua sensor modules under their own labels. Buyers must verify the component supply chain, not just the brand name on the housing. The FCC's Covered List and the Department of Defense's 1260H List provide starting points, but neither is exhaustive.

Integrated platforms. Vendors increasingly offer converged platforms combining intrusion detection, video management, and access control. If any subsystem includes a covered component, the entire platform may be non-compliant under Part B.

Legacy installations. Facilities upgrading perimeter detection may have existing Hikvision or Dahua cameras on-site. Under Part B, the presence of covered equipment anywhere in the contractor's operations — not just on the specific federal contract — can create compliance exposure.

International supply chains. PIDS projects with components manufactured in or transiting through China face additional scrutiny under the Trade Agreements Act (TAA), which requires products to be manufactured or substantially transformed in a TAA-designated country.

The 1260H List and What Comes Next

The Department of Defense maintains the Section 1260H list of Chinese military companies, updated annually. While the current list primarily targets telecommunications and semiconductor companies, the expanding scope of the list — and growing legislative interest in extending prohibitions to additional surveillance technology categories — signals potential future restrictions on sensor and radar components with Chinese origins.

Defence contractors should watch for enforcement of Section 1260H beginning June 2026, which will require additional compliance certification.

Practical Steps for PIDS Procurement

For organizations procuring perimeter detection systems for federal or federally-adjacent projects:

Require NDAA/TAA compliance declarations from all vendors at the RFP stage. Verify camera and sensor component origins independently — do not rely solely on vendor self-certification. Audit existing installations for covered equipment before awarding new contracts that may trigger Part B exposure. Track the 1260H list and emerging legislation for changes to the covered entity scope.

Section 889 compliance is not a one-time checkbox. It is an ongoing supply chain obligation that shapes which PIDS vendors can compete for an expanding share of the perimeter security market.