Section 889 — the five banned vendors
FY2019 NDAA §889 (Pub. L. 115-232), implemented by FAR 52.204-25, names exactly five covered companies — plus their subsidiaries and affiliates. Not "5 + 2 others." SZL Holdings represents that it neither provides nor uses covered equipment from any of them.
The covered companies (§889(f)(3))
| Company | Category | Statute |
|---|---|---|
| Huawei Technologies Company | telecommunications | §889(f)(3)(A) |
| ZTE Corporation | telecommunications | §889(f)(3)(A) |
| Hytera Communications Corporation | two-way radio / LMR | §889(f)(3)(B) |
| Hangzhou Hikvision Digital Technology Company | video surveillance | §889(f)(3)(B) |
| Dahua Technology Company | video surveillance | §889(f)(3)(B) |
(A) Telecommunications: Huawei, ZTE. (B) Video surveillance & public-safety: Hytera, Hikvision, Dahua. The prohibition extends to subsidiaries and affiliates of these five.
SZL Holdings representation
SZL Holdings does not provide or use covered telecommunications or video-surveillance equipment or services from Huawei, ZTE, Hytera, Hikvision, or Dahua (or their subsidiaries/affiliates) as a substantial or essential component of any system, or as critical technology.
- The mesh runs on mainstream commercial cloud and CNCF-certified Kubernetes (k3s/RKE2) and air-gapped single-node hardware.
- No Huawei/ZTE telecom gear; no Hikvision/Dahua surveillance gear; no Hytera radios as components — on bench, build, or runtime.
- Any covered item discovered during performance is reported to the contracting officer within one (1) business day (per FAR).
Part A (§889(a)(1)(A), effective Aug 13 2019) bars the government from procuring covered gear. Part B (§889(a)(1)(B), effective Aug 13 2020) bars the government from contracting with entities that use covered gear, regardless of whether that use is under a federal contract.
Verifiable evidence
- Plain-language Section 889 explainer: U.S. Election Assistance Commission — What is Section 889
- FAR 52.204-25 (prohibition clause): acquisition.gov/far/52.204-25
- FAR 52.204-26 (representation): acquisition.gov/far/52.204-26
- Killinchu signed representation lives in the source repo's
.compliance/SECTION_889_REP.md(DCO-signed; founder e-signature at award).