1. Background

Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 restricts the U.S. government, its contractors, and recipients of federal grants and loans from procuring or using certain telecommunications and video surveillance equipment and services. Covered sources are Huawei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, and Dahua Technology Company, including their subsidiaries and affiliates. The restriction also applies when covered equipment is sold under another manufacturer’s brand, as in OEM, ODM, and JDM arrangements.

2. ZKTeco USA Position

ZKTeco manufactures both NDAA-compliant and non-NDAA-compliant video surveillance equipment. All ZKTeco access control panels and readers shipped by ZKTeco USA after January 1, 2022 are NDAA compliant.

3. Supply Chain

Products identified as NDAA compliant contain no components produced by the covered entities above. ZKTeco has no OEM, ODM, or JDM relationship with those entities for products supplied by ZKTeco USA.

4. Customer Requests

Customers who require NDAA-compliant equipment should tell their ZKTeco USA supplier at the time of inquiry and request the appropriate product recommendation.

5. System-Level Responsibility

Section 889 compliance is not a certification issued by the U.S. government. Compliance depends on the full system, so customers should confirm that all components, including third-party cameras and recorders, meet their requirements.

Notice

This NDAA compliance statement is for informational purposes only. It reflects ZKTeco’s current understanding of NDAA compliance and may change without notice, accordingly. It is not legal advice.