NDAA-Compliant Security Camera Installation in Virginia

Where most buyers get caught: rebadged hardware

Section 889 names five manufacturers, but those manufacturers also build cameras and recorders that ship under other companies' labels. A line sheet can be entirely free of the five named brands and still be full of their hardware. If you are buying on a federal contract, taking federal grant money, or signing a contract that carries FAR 52.204-25, the label on the bezel is not what matters. The original equipment manufacturer is.

We are a Virginia Class A contractor (#2705190126, ESC and FAS specialties) and a DCJS-licensed electronic security business (#11-20830), registered for federal work with CAGE code 9RF35 and UEI E364ZNKQ7SP8. We are based in Virginia Beach and work across the Commonwealth. The rest of our federal registration detail is on the government and federal contracting page.

What does Section 889 prohibit?

Section 889 of Public Law 115-232 has two parts, and they land on different people.

Part (a)(1)(A), effective August 13, 2019, stops federal agencies from buying covered telecommunications and video surveillance equipment or services. This is the part people usually mean when they say NDAA compliant. It governs what an agency may procure.

Part (a)(1)(B), effective August 13, 2020, is the broader one. It stops federal agencies from entering into or renewing a contract with any entity that uses covered equipment as a substantial or essential component of any system, whether or not that equipment has anything to do with the federal contract. A manufacturer with Hikvision cameras in its own parking lot can lose its eligibility to hold a federal contract.

The clauses that implement this are FAR 52.204-24, 52.204-25 and 52.204-26. If you are a prime or a sub on federal work, you have almost certainly represented something about this in writing already.

Who has to comply besides federal agencies?

Defense contractors and their supply chains, any organization spending federal grant money (school divisions, municipalities, transit authorities, public health systems, airports), and private companies that hold or want to hold federal contracts. In Hampton Roads, with the shipyards and the bases, that reaches a large share of ordinary commercial buildings.

NDAA compliance and TAA compliance are separate rules

These two get conflated constantly, including by people selling cameras.

NDAA Section 889 is about who made it. It bans equipment from five specific Chinese manufacturers and their affiliates on national security grounds. A camera made in Vietnam by a company with no connection to those five is NDAA compliant.

The Trade Agreements Act is about where it was made. It requires that end products come from the United States or a designated country. A camera can be fully NDAA compliant and still fail TAA, and the reverse happens too.

Some contracts require one. Some require both. We read the clauses in your solicitation and tell you which applies before we quote, rather than after you have bought.

What we install instead

Our video line is built on manufacturers that are clean under Section 889 at the OEM level:

• Hanwha Vision, a Korean manufacturer, is our primary line for commercial and government IP video, held on an authorized dealership.
• Bosch, a German manufacturer, where the specification calls for it or the environment is demanding.
• Alarm.com, the US-based cloud video and alarm platform, on an authorized dealership.
• Capture Advance, Eclipse and Luma, used selectively on commercial and residential work and checked model by model.

Every camera, recorder, switch and access point we specify on a compliance-sensitive project comes with manufacturer documentation of its Section 889 status, handed over in the closeout package. For the rest of the system, see security camera installation and access control.

Replacing covered equipment you already have

A good share of this work is replacement rather than new installation: an organization discovers that the cameras it inherited, or bought cheaply in 2018, are covered equipment, and it now has a contract or a grant condition that will not tolerate them.

That job is usually less painful than people expect. The cable plant is normally reusable, the mounting locations are already proven, and on a PoE system the swap is often camera-for-camera on the existing drops. We survey what you have, tell you honestly what has to go and what can stay, and phase the replacement so you are never fully dark. If what you have is compliant and someone has told you otherwise to sell you a system, we will tell you that too.

Book a free on-site consult and send the clause list from your contract ahead of the visit.