Section 889 of the 2019 National Defense Authorization Act

Pursuant to Section 889 of the National Defense Authorization Act of 2019 (“NDAA”), federal contractors, including Emory University, are subject to prohibitions involving certain covered telecommunications equipment or services produced by certain China-based companies and their subsidiaries or affiliates.

Federal contractors are currently prohibited from providing covered equipment and services to the US government (Part A, effective August 13, 2019), and using covered equipment and services, even if the equipment is not used in the performance of a federal contract, (Part B, effective August 13, 2020). 

Covered Telecommunications Equipment and Services

Examples of “covered telecommunications equipment and services” includes: 

  • Cellphones and tablets; 
  • Video surveillance cameras; 
  • Network routers and switches; and 
  • Telecommunications or video surveillance services provided by prohibited entities or using equipment produced by prohibited entities 

Prohibited Entities

Currently, the prohibited entities under the regulations are: 

  • Huawei Technologies Company 
  • ZTE Corporation 
  • Hytera Communications Corporation 
  • Hangzhou Hikvision Digital Technology Company 
  • Dahua Technology Company 
  • Affiliates and subsidiaries of the above 

Responsibilities of All Emory Personnel

Emory personnel are prohibited from purchasing covered equipment or services or using covered equipment or services for Emory business, regardless of funding source or relationship to a federal contract or grant. Personal devices that qualify as covered equipment cannot be used for Emory business, including basic email communication, and cannot be connected to Emory networks for any purpose.  

The list of prohibited companies has been added to Visual Compliance, the software Emory uses to screen vendors. All vendors should be screened using Visual Compliance to ensure they are not on any prohibited list.  

Please contact Emory’s Export Control Office for help with Visual Compliance, or with any other questions.

Please contact the Office of Sponsored Programs if you are required to make a representation (i.e., certify) to the US government that you are (or Emory is) in compliance with NDAA Section 889.

Frequently Asked Questions

No and no. Please do not use a personal device (e.g., Huawei cellphone) produced by a prohibited entity for Emory business. Emory policy prohibits connecting a personal device to Emory networks regardless of purpose.

Yes. The prohibition is intentionally broad and applies to Emory as a whole. Even if an activity is unrelated to a federal contract or grant, the prohibition still applies. By virtue of being Emory personnel, the requirement extends to you.

Yes. If the equipment or services are still being used or will be used in the future, it does not matter when they were purchased.

Contact John Ellis, Deputy CIO, at Please do not take any action on your own.

Contact the Export Control Office for assistance in resolving a potential positive hit.