Section 889 of the FY2019 National Defense Authorization Act is the clause that decides whether a thermal camera can be bought on a federal order at all, and it attaches to the equipment, not to the store selling it. This guide covers what the rule prohibits, why two of the most common thermography brand families are affected, how aerial thermal adds a second rule on top, and how to tell which listings in this catalog clear it.

What Section 889 actually prohibits

The rule has two halves, and buyers usually quote only the first.

Part A (effective August 13, 2019) bars a federal agency from procuring, obtaining, extending or renewing a contract to procure or obtain any equipment, system or service that uses covered telecommunications or video surveillance equipment as a substantial or essential component, or as critical technology in any system.

Part B (effective August 13, 2020) bars an agency from contracting with any entity that uses that equipment — which is the half that reaches resellers, integrators and service providers, and the reason the clause flows down into subcontracts as FAR 52.204-25.

"Covered" means equipment or services produced or provided by Huawei, ZTE, Hytera, Hikvision or Dahua, including their subsidiaries and affiliates. Two consequences matter when you are assembling a purchasing file:

  • The prohibition follows the manufacturer of the equipment, not the invoice. A U.S. dealer, a U.S. warehouse and a U.S. warranty do not change what the camera is.
  • A camera can be entirely legal to own and still be ineligible for a federal purchase. The restriction is on procurement, not possession.

Why thermography brands are named

HIKMICRO is a Hikvision brand family. Hikvision-branded and HIKMICRO-branded thermal cameras are therefore covered equipment, and the restriction follows the brand family rather than the label on the housing. Dahua-branded thermal cameras are covered for the same reason.

We do not list Hikvision, HIKMICRO or Dahua thermal cameras in this catalog, and a camera from that family cannot be made compliant by buying it from a domestic reseller. If a competing quote includes one on a federal order, the clause is failed regardless of who signs the invoice.

Everything else in the market has to be judged on evidence rather than on a list, which is the harder half of the job and the subject of the next section.

The drone layer: a second rule on top

Aerial thermal carries an additional restriction. The FY2024 NDAA's American Security Drone Act bars federal agencies from procuring unmanned aircraft manufactured in a covered foreign country, or that contain critical components from one, and the Department of Defense's Chinese military companies list names DJI. So a DJI or Autel aircraft is not a federal option even though neither is one of the five Section 889 vendors.

For a drone purchase, both tests have to pass: the aircraft, and the thermal payload on it. A compliant payload on a non-compliant airframe is still a non-compliant system.

How this catalog flags it

Compliance is recorded per listing rather than claimed for the store, because it is a property of the specific camera and its manufacturer.

At the time of writing, 98 of the 302 listings in the catalog carry the NDAA §889 flag, from 12 manufacturers: Inspired Flight (17), WISPR (17), MicaSense (10), SIG SAUER (10), Trijicon (10), ACSL (9), Freefly (8), Teledyne FLIR (7), Sentera (5), GreenValley International (3), GeoCue (1) and FoxFury (1). Every one of them is based in the United States or a treaty ally and is not a covered entity, nor owned or controlled by one.

A listing is flagged only once its manufacturer's origin and ownership have been checked. That means an unflagged listing is unverified, not non-compliant — ATN, AGM Global Vision, Onick, Thermal Master, DJI, Autel and GDU all sit unverified today, and several of them may well clear the rule once their documentation is in hand. We confirm the status in writing with the manufacturer before an order is accepted rather than guessing on the page.

To isolate the flagged listings, open the catalog and switch on NDAA §889 compliant in the quick filters. The same flag is shown on each product page beside the price.

TAA is a separate test

Section 889 asks who made the camera. The Trade Agreements Act asks where it was manufactured or substantially transformed, and GSA Schedule and most federal purchases require both. A camera designed in the United States but built in China can pass Section 889 and fail TAA.

We record TAA per listing on the same basis as the NDAA flag, and no listing carries the TAA flag yet while manufacturer country-of-origin documentation is collected. Treat TAA status as confirmed on the quote, not inferred from the storefront. Export controls are a third, separate question and are documented on the export compliance page.

What to put in the contract file

  1. The flagged listing, printed with the quote. The flag and its date are the record of what was verified at the time of the order.
  2. The manufacturer's written Section 889 statement, naming the brand family and confirming no covered vendor is a substantial or essential component.
  3. A country-of-origin letter if the order requires TAA compliance.
  4. For an aircraft, the drone statement — country of manufacture and component origin.
  5. A firmware and cloud note where the camera depends on a vendor portal, so the reviewing officer can see no covered vendor sits behind it.

We supply the first and request the rest from the manufacturer as part of the quote. We are a supplier, not your contracting officer, so the final determination stays with your contracting and legal review.

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