Two acronyms decide whether a piece of network hardware can be sold into a US government contract, and resellers routinely confuse them. They are not the same rule, they do not apply to the same deals, and satisfying one does not satisfy the other.
TAA: where the product was made
The Trade Agreements Act governs country of origin. A product is TAA compliant if it was wholly manufactured, or “substantially transformed”, in the United States or in a designated country — broadly, countries the US holds a trade agreement with. China is not a designated country. Neither is India, and that catches people out.
TAA applies to procurements above the relevant dollar threshold under the Federal Acquisition Regulation. Below that threshold, the Buy American Act generally applies instead, with different arithmetic.
The practical trap: TAA status is per lot, not per part number. A manufacturer may build the same SKU in two countries. The part number does not change. The compliance status does. This is why we confirm TAA in writing against the specific lot you are buying, rather than pointing at a datasheet.
NDAA: who made it
Section 889 of the 2019 National Defense Authorization Act is about vendors, not geography. It prohibits federal agencies from procuring covered telecommunications and video surveillance equipment from a named list of companies, and from contracting with entities that use that equipment.
The named companies most relevant to network resellers are Huawei, ZTE, Hytera, Hikvision and Dahua — and, critically, any subsidiary or affiliate of them. That last clause is the one that catches resellers, because a great deal of white-label camera and networking hardware is manufactured on those OEM lines and sold under a different brand.
Part B of Section 889 goes further: an agency cannot contract with a company that uses covered equipment anywhere in its own operations. If your own warehouse runs Hikvision cameras, that is a problem for your federal eligibility independent of what you sell.
What evidence is actually accepted
| Requirement | What satisfies it | What does not |
|---|---|---|
| TAA country of origin | Manufacturer letter of volatility or origin statement naming the specific lot or serial range | A datasheet, a marketing page, or a distributor’s verbal assurance |
| NDAA 889 Part A | Manufacturer written attestation that the product contains no covered equipment | Absence of a covered brand name on the box |
| NDAA 889 Part B | Your own written representation in SAM.gov | Anything your supplier gives you |
| Chain of custody | Unbroken invoice trail from manufacturer or authorised distributor to you | A purchase receipt from a marketplace or broker |
Where resellers get caught
- Assuming a compliant brand means a compliant product. Several major brands ship both compliant and non-compliant variants of the same model. The compliant one usually carries a different suffix — and costs more.
- Buying refurbished for a federal contract. Refurbished hardware rarely carries a defensible origin statement, and the original manufacturer will not issue one for a unit that has passed through third parties.
- Relying on a broker’s word. If a contracting officer asks for evidence and all you have is an email from someone who bought it from someone else, you do not have evidence.
- Ignoring Part B. Selling compliant product while running covered equipment in your own building still disqualifies you.
How we handle it
TAA-eligible lines on our card are marked and filterable. When you quote one for a federal or SLED deal, tell us at quote stage. We confirm origin against the actual lot before we allocate it, and the confirmation goes on the quote in writing. If we cannot confirm it, we say the line is not TAA rather than letting you find out during a protest.
We do not carry Section 889 covered equipment on the surveillance card at all. That is why the camera lines are Axis and Ubiquiti rather than the cheaper alternatives — the cheaper alternatives are frequently unsellable in the market our buyers are aiming at.