Federal Procurement Restrictions

Equipment, Software, and Other Items Restricted for Procurement or Use in Connection with Sponsored Research

Federal regulations prohibit the procurement or use of certain non-U.S. goods and services. University researchers must not buy or operate prohibited items in connection with sponsored projects, as detailed below. Please direct any questions or concerns regarding these restrictions to the Export Controls and Research Security team (ECRS) at [email protected].

General FASCSA Prohibition

Federal Acquisition Regulation (FAR) 52.204-30 prohibits “providing or using as part of the performance of the contract any covered article, or any products or services produced or provided by a source” identified in an order issued under the Federal Acquisition Supply Chain Security Act (FASCSA).  These orders must be published on the website for the System for Award Management.

As of June 2025, the U.S. Government has not issued any FASCSA orders, but is expected to do so in the near future. 

Prohibited Foreign-Made Unmanned Aircraft Systems (UASs)

Effective December 22, 2025, grantees and contractors may not buy or even use prohibited UASs in connection with federal sponsored projects of any sort.  The prohibited UASs are those manufactured by companies located in countries of concern and identified in the government’s FASCSA system.

UAS manufacturers from which is it is safe to buy include:
 

  • AgEagle (USA)
  • American Robotics (USA)
  • Anduril (USA)
  • Ascent Aerosystems (USA)
  • Blue Halo (USA)
  • Draganfly (Canada)
  • Easy Aerial (USA)
  • Edge Autonomy (USA)
  • Flightwave Aerospace (USA)
  • Freefly Systems (USA)
     
  • Harris Aerial (USA)
  • Hoverfly Technologies (USA)
  • ideaForge (India)
  • Impossible Aerospace (USA)
  • Insitu (USA)
  • Inspired Flight Technologies (USA)
  • ModalAI (USA)
  • Neros Technologies (USA)
  • Parrot (France)
  • PDW (USA)
  • Quantum Systems (Germany)
  • Schiebel (Austria)
  • Skydio (USA)
  • Skyfish (USA)
  • Teal (USA)
  • UAVAmerica (USA)
  • Vantage (USA)
  • Wingtra (Switzerland)
  • WingXpand (USA)
  • Zone 5 Technologies (USA)
     

Prohibited Telecommunications and Surveillance Equipment and Services

Federal grantees and contractors may not purchase or make use of the following equipment:

Telecommunications equipment produced by:

  • Huawei Technologies Company,
  • ZTE Corporation, or
  • any subsidiary or affiliate of these organizations; and

Video surveillance and telecommunications equipment produced by: 

  • Hangzhou Hikvision Digital Technology Company,
  • Dahua Technology Company,
  • Hytera Communications Corporation, or
  • any subsidiary or affiliate of these organizations

For a full working list of off-limits subsidiaries and affiliates of these companies, please see the .
 

Prohibited Software and Apps

  • Kaspersky Software: Contractors and grantees are prohibited from buying or using anti-virus software and cybersecurity services from Kaspersky Lab or any of its subsidiaries or affiliates.
  • ByteDance/TikTok: Contractors and grantees are prohibited from “having or using the social networking service TikTok or any successor application or service developed or provided by ByteDance Limited or an entity owned by ByteDance Limited” on any device used in the performance of federal contracts, including personal devices used for such contracts.
     

Genomic Service Providers of Concern

While there are currently no laws in place comprehensively prohibiting engagements with certain genomic service providers, restrictions from legislation such as the BIOSECURE Act are likely to emerge in the future. Moreover, federal officials have expressed specific concerns about several such providers.

Research personnel should not utilize the services of the following companies or their affiliates or subsidiaries:

  • BGI (Beijing Genomics Institute) (subject to export restrictions)
  • MGI Tech
  • Complete Genomics
  • WuXi AppTec