Solutions
TAA & NDAA-889 Compliance Screening for IT Procurement
Two rules decide whether an IT purchase clears procurement review — where a product was made, and who made it. Uniqcli performs TAA (FAR 52.225-5) and NDAA §889 screening on every order, line by line, before the quote goes out.
- Screening
- TAA (FAR 52.225-5) & NDAA §889, every order
- Authorities
- FAR subpart 25.4 · FAR subpart 4.21
- Scope
- IT hardware, components, software and licensing
- Boundary
- A screening service — never a certification we hold
Two rules, two different questions — screened before the quote goes out
The Trade Agreements Act turns on where a product was made. Section 889 of the FY2019 National Defense Authorization Act turns on who made it. One is gated by an acquisition threshold and a contract clause; the other applies at any dollar value, down to a single card buy. Neither is a label a manufacturer prints on a box; both are questions about a specific purchase. Uniqcli performs TAA and NDAA §889 screening on every order — country of origin recorded per line, each manufacturer and its affiliates checked against the covered-entity list, the result reflected in what we quote. The determination on your award stays with your contracting officer; the diligence behind it is ours to run.
What the two rules actually require
Both are conditions on a procurement, not product certifications — so both are screened per line.
TAA — country of origin
The Trade Agreements Act, implemented at FAR subpart 25.4, restricts what a federal buyer may acquire once the acquisition exceeds the applicable threshold and the Trade Agreements clause, FAR 52.225-5, is in the contract. The end product must be a U.S.-made or designated-country end product — wholly manufactured there, or substantially transformed there into a new article with a different name, character or use. FAR 25.003 defines the designated list — WTO Government Procurement Agreement members, free trade agreement partners, least-developed countries and Caribbean Basin countries.
NDAA §889(a)(1)(A) — covered equipment
Effective August 13, 2019 and implemented at FAR subpart 4.21 with clause FAR 52.204-25, this half bars a federal agency from procuring covered telecommunications or video-surveillance equipment or services — or any system that uses them as a substantial or essential component, or as critical technology. Because the test is about the technology doing the work inside, a rebadged module from a covered maker is in scope even when the badge is not. The named makers are Huawei and ZTE, and — for public-safety or security video surveillance — Hytera, Hangzhou Hikvision and Dahua, together with their subsidiaries and affiliates. There is no low-dollar exemption from the prohibition itself; it reaches at or below the micro-purchase level (FAR 13.201(j)).
NDAA §889(a)(1)(B) — use by the contractor
Effective August 13, 2020, this half reaches past what is being sold to what the offeror itself uses, which is why entities represent their status through FAR 52.204-24 at the offer and FAR 52.204-26 annually in SAM.gov, backed by a documented reasonable inquiry. The representation is made by the offeror or contractor, not by a reseller; what a reseller can supply is the maker, module and country-of-origin record that supports it.
Screening is diligence on the goods, not a badge on the seller
There is no such thing as a TAA-certified reseller, and no manufacturer issues a §889 badge for an individual part. What exists is diligence — performed per line: the manufacturer-stated country of origin, and the maker with its parent and affiliates checked against the covered-entity list.
That work happens before a quote leaves, not after an award is questioned. When a line does not survive the check — origin unstated, origin outside the designated list, maker or affiliate on the covered list — we flag it and offer alternates in the same category rather than quietly quoting it. If your internal policy is stricter than the statute, tell us the rule you work to and we screen to yours.
- TAA & NDAA-889 screening performed on every order, line by line
- Manufacturer-stated country of origin recorded, never inferred
- Maker, parent and affiliates checked against the §889 covered list
- Failing lines flagged before the quote, with alternates proposed
- Screening results available with your quote on request
From requirement to screened order
- Send a requirement, a bill of materials or a spreadsheet of part numbers
- Off-catalog lines are sourced by RFQ through authorized US distribution
- Screening runs before the quote goes out; anything that fails is flagged with alternates
- Quotes, orders, approvals and documents live in your buyer portal
- GPC / P-Card accepted up to your cardholder threshold; POs otherwise
- Stock and final total confirmed before you commit; free US shipping over $2,500
Screening sits inside a wider compliance picture
Origin and covered-entity screening answer two questions about a purchase. What a CUI environment has to implement around that purchase is a separate control set — set out family by family on the CMMC pages.
TAA and §889 screening questions
Are your products TAA-certified?
No product is, and no vendor holds a TAA certification — the term does not exist in the FAR. TAA compliance is a determination about a specific end product under a specific contract, made by the buyer and the contracting officer. What we provide is screening on every order: manufacturer-stated country of origin per line, measured against the designated-country test in FAR 25.003, performed before the quote goes out.
Does Section 889 apply to a small card purchase?
Yes. The substantive prohibition applies regardless of acquisition size and reaches at or below the micro-purchase level (FAR 13.201(j)), even though the separate offeror representation is generally not collected on very low-dollar buys. The absence of a signed representation is not an exemption — which is why we screen every line on every order.
What happens if a part we specified fails the screen?
We flag it before the quote goes out and propose alternates in the same category, screened the same way. Nothing is substituted without your approval, and brand-name-or-equal justification is available on request.
Do you screen software and licensing too?
Yes. The publisher and its affiliates are checked against the covered-entity list exactly as a hardware maker is, and we record what the publisher states about origin. Where nothing is published, we say so rather than filling the gap with an assumption.
How do we buy once the screening is clear?
Through a quote or RFQ. Send the requirement or the bill of materials, we return one consolidated quote with screening complete, and you approve it in the buyer portal. GPC / P-Card is accepted up to your cardholder threshold; standard purchase orders otherwise.
Procurement
Screened before it is quoted.
TAA & NDAA-889 screening performed on every order — country of origin recorded per line, covered-entity checks documented, alternates proposed before the quote goes out.
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Talk to us about a screened order
Send a bill of materials, a part list or the requirement behind it. We return one consolidated quote with TAA (FAR 52.225-5) and NDAA §889 screening performed per line — anything that does not clear is flagged before you commit.