How to Complete the Lowe’s 889 Form: SAM.gov Filing and Flow-Down

The Section 889 representation is a self-certification federal contractors submit in SAM.gov confirming that their company neither provides nor uses covered telecommunications or video surveillance equipment from certain banned manufacturers. You complete it under FAR 52.204-26 in your entity’s Representations and Certifications, and you refresh it at least once a year. Without a current affirmative representation on file, your business cannot compete for most federal contracts or receive federal payments above the $15,000 micro-purchase threshold.¹

What You Are Certifying

The representation asks two yes-or-no questions. First, whether your company provides covered telecommunications equipment or services to the government in performance of any contract. Second, whether your company uses covered telecommunications equipment or services, or any system that incorporates them, anywhere in its operations.²

“Covered” points to a specific list. The statute names five Chinese manufacturers at its core: Huawei, ZTE, Hytera, Hikvision, and Dahua. The ban reaches their subsidiaries and affiliates, and it extends to any entity the Secretary of Defense identifies as owned or controlled by a covered foreign country.³

Covered equipment includes routers, switches, and other network hardware that routes or allows viewing of user data, along with video surveillance cameras and services used for public safety or facility security. For a piece of hardware to trigger the prohibition, it must function as a “substantial or essential component” of a system or qualify as “critical technology” within a system. A substantial or essential component is any part necessary for the proper function or performance of the equipment.³

The second question is the one that catches contractors off guard. It reaches your entire enterprise, not just the division doing federal work. A Hikvision camera in a regional office unconnected to any federal contract still forces a “does” answer.

Conduct a Reasonable Inquiry First

Before you check either box, the regulation requires a “reasonable inquiry.” FAR 52.204-25 defines it as an inquiry designed to uncover information already in the entity’s possession about the identity of the producer or provider of covered equipment. It explicitly excludes any need for an internal or third-party audit.³

In practice, that means working from records you already have: purchase orders, invoices, technical specifications from your IT vendors, and hardware inventory lists. Check brand labels and model numbers against the five named companies and their known affiliates. Watch for white-label products where a banned manufacturer built the hardware and another company rebranded it.

Cover the whole organization. Document what you reviewed and when, so you can show due diligence later if a contracting officer or investigator asks.

Filing the Representation in SAM.gov

Log in to SAM.gov and open your entity registration. The Section 889 fields sit in the Representations and Certifications section of your entity profile, under the FAR 52.204-26 provision.⁴ You will need your legal business name and Unique Entity Identifier (UEI) to reach the record.

Complete the two representations:

Whether your company provides covered telecommunications equipment or services to the government in performance of any contract.
Whether your company uses covered telecommunications equipment or services, or any system that incorporates them.

Most contractors will check “does not” for both. If your inquiry turned up covered equipment, check “does” for the applicable question and prepare for the additional disclosure that comes at the solicitation stage.

The representation is effective for one year from the date you submit or update it, and you must review and refresh it at least annually to keep it current.⁵ After you submit, SAM.gov can take up to 10 business days to process the change and mark the profile active.⁶ Contracting officers and purchase cardholders can look up your status through GSA’s dedicated search tool, which pulls directly from your SAM.gov record.⁷

If your SAM.gov profile is not yet updated and a solicitation is in front of you, you can submit a manual representation directly to the contracting officer. This is common for vendors newly entering the federal marketplace or for emergency procurements. Keep a copy of the manual submission and the contracting officer’s acknowledgment.

When a Solicitation Asks Again

A second clause, FAR 52.204-24, appears inside individual solicitations. It asks the same two questions but calls for additional disclosure if either answer is affirmative. The useful shortcut: if you already represented “does not” to both questions in SAM.gov under FAR 52.204-26, you do not need to complete the corresponding portions of FAR 52.204-24 for that solicitation.⁸

If you do answer affirmatively at the solicitation level, you must disclose additional details: what the equipment is, how it is used, and where it sits in contract performance. That is where model numbers, manufacturer names, and descriptions of use become relevant. The disclosure goes to the contracting officer running that specific procurement.⁸

Flow-Down to Subcontractors

FAR 52.204-25 flows down to subcontractors at all tiers. If you are the prime, you carry responsibility for making sure your subcontractors also comply with the ban on covered equipment and services.³

That means including the clause in your subcontracts and requiring your subs to run their own reasonable inquiries. Reporting duties travel the same path. If a subcontractor at any tier finds covered equipment during contract performance, the reporting clock starts for both the subcontractor and the prime. Building this language into standard subcontract templates saves time later.

If You Find Covered Equipment After Award

Discovering banned equipment after a contract is already in place triggers a specific reporting sequence under FAR 52.204-25. The contractor must notify the contracting officer immediately with an initial report that includes:

The manufacturer name.
The model number and product code, if known.
A description of the equipment or service and how it is used in contract performance.
The contract number and task or delivery order number, if applicable.
Any actions already taken or recommended to address the issue.

Within 10 business days of the initial report, a follow-up report is due. It must include additional information uncovered since the first report, a description of efforts to prevent further use of the covered equipment, and any remedial actions planned or completed.³

Speed matters. The gap between discovering a problem and reporting it is one of the things contracting officers and investigators scrutinize most closely. Document the discovery date, who identified the issue, and when the report went out.

What a Wrong Answer Costs

An inaccurate representation is a breach of contract and can lead to cancellation, termination, and financial liability.⁹

A knowingly false certification can also trigger civil liability under the False Claims Act. Current inflation-adjusted penalties range from $14,308 to $28,619 per false claim, plus treble damages on any losses the government suffers.¹⁰ Suspension and debarment from all future government contracting are also on the table for serious or repeated violations.

Waivers Are No Longer an Option

Section 889 originally included a one-time waiver allowing agency heads to grant additional time for a contractor to phase out covered equipment. The statutory waiver authority for Part B expired on August 13, 2022.⁹ Contractors today cannot rely on a waiver to keep using covered equipment while competing for or performing under federal contracts. If banned technology is still in your environment, the path forward is removal and replacement before you file or renew your representation.

1
Federal Register. Inflation Adjustment of Acquisition-Related Thresholds
2
Acquisition.GOV. 48 CFR 52.204-26 – Covered Telecommunications Equipment or Services-Representation
3
Acquisition.GOV. Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment
4
Acquisition.GOV. AFARS – 6-3. National Defense Authorization Act Section 889 Representation
5
Acquisition.GOV. Subpart 4.12 – Representations and Certifications
6
SAM.gov. Entity Registration
7
General Services Administration. 889 Representations Search
8
Acquisition.GOV. 52.204-24 Representation Regarding Certain Telecommunications and Video Surveillance Services or Equipment
9
Federal Register. Federal Acquisition Regulation: Prohibition on Contracting With Entities Using Certain Telecommunications and Video Surveillance Services or Equipment
10
Federal Register. Civil Monetary Penalties Inflation Adjustments for 2025