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Federal Procurement and Use Restrictions for Software, Equipment, and Other Items
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 Office of Research Integrity (ORI) at composp@uccs.edu.
Non-compliance may result in contract termination, legal penalties, and loss of federal funding. Timely action is essential to ensure alignment with these federal mandates.
Prohibited Telecommunications and Surveillance Equipment and Services
Campus does not support the purchase or use of these items on any University systems regardless of funding, FAR 52.204-25:
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
Please contact the UCCS Office of Research Integrity (ORI) or Office of Information Security (OIT) if you have questions.
Prohibited Software and Apps
Campus does not support the purchase or use of the following software and apps as directed below:
- 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.
Prohibited Foreign-Made Unmanned Aircraft Systems (UASs)
Effective December 22, 2025, FAR 52.240-1, grantees and contractors may not buy or even use prohibited UASs in connection with federal sponsored projects of any sort. Prohibited UASs are those manufactured by companies located in countries of concern and identified in the government’s Federal Acquisition Supply Chain Security Act (FASCSA) system. FASCSA prohibits contractors from “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, if the prohibition is set out in an applicable FASCSA order."
Note - The American Security Drone Act (ASDA)-Covered Foreign Entity List FASC "covered foreign entity" list does not include any other entities at this time, but EO 14307 (PDF) published on 6/6/2025 requires the publication of a Covered Foreign Entity List (i.e., FASC-prohibited UAS companies) by July 6.
FAR 52.240-1 Key Points:
- Prohibited Drones: Contractors may not deliver, use, or procure any UAS from ASDA-covered entities in the performance of federal contracts where the FAR clause 52.240-1 is included in the award. It is anticipated that this clause will be included in all federal contracts moving forward.
- Compliance: All federally funded projects must ensure compliance with these regulations to avoid potential penalties (including debarment) or loss of funding.
- Implementation Date: These restrictions will take effect on December 22, 2025.
- Grandfathering: Currently, there is no option to grandfather in drones.
- These restrictions must be flowed down to all subcontractors.
DoD 1260H Prohibited Entities
The Department of Defense established the DoD 1260H List, under the William M. (Mac) Thornberry National Defense Authorization Act (NDAA) for Fiscal Year 2021, identifying Chinese Military Companies operating in the United States. The DoD recently updated this list on Jan. 7, 2025 to include UAS manufacturers such as:
- DJI (Shenzhen DJI Innovation Technology Co., Ltd.),
- Autel Robotics Co., Ltd., and
- Aerospace CH UAV Co., Ltd.
Compliance Requirements
- Contractors must ensure that no UAS or related components from listed companies are used in DoD-funded projects.
- DJI, Autel, and other restricted UAS brands are strictly prohibited on DoD-funded projects.
Other Federal Agency Regulations
In addition to FAR 52.240-1 and DoD restrictions, other federal agencies have similar requirements regarding UAS and related communication components:
- For example, the U.S. Department of Energy requires that unmanned aircraft as well as other communication components made or manufactured in a foreign country of risk be disclosed to the sponsoring federal agency at the time of proposal and throughout the lifetime of the award.
Steps For Compliance
- To ensure compliance with both requirements, it is recommended to use drones from manufacturers listed on the DoD Blue UAS Cleared List, which includes DoD-vetted manufacturers.
- Review all drones and related components against the SAM (FASC) and 1260H lists before purchase or use in federal research or DoD-funded projects. This can be accomplished by screening in Visual Compliance, where these lists are included.
- Cease operations using prohibited UAS before December 22, 2025, for any federal award whether the FAR clause applies or DoD contract.
- Update internal procurement policies to restrict acquisition from banned manufacturers for all federally funded research and DoD projects.
- Ensure that all subcontractors involved in federal research or DoD projects are informed and compliant.
- Visit the Drone Export Control and Know Before You Fly websites for additional information.
... I have a DoD Contract.
If you are working on a DoD–funded contract or grant, you are legally required to comply with all applicable drone restrictions outlined in the NDAAs and Federal Acquisition Regulations. This means you cannot purchase, operate, or use drones (including DJI and other foreign-manufactured systems) in connection with your project—even for data collection, testing, or training—unless they are explicitly approved under the DoD’s Blue UAS program.
A full list of restricted foreign companies can be found in the “American Security Drone Act-covered foreign entities” list.
... I have a federally funded (non-DoD) contract.
Drone use in federally funded research—such as projects supported by NSF, NIH, DOE, or NASA—is governed by restrictions originating from the National Defense Authorization Acts (NDAAs) and enforced through the Federal Acquisition Regulation (FAR). These rules prohibit the use of federal funds to purchase or operate drones from certain foreign manufacturers, including DJI, regardless of when the equipment was acquired. A transition period is in place, requiring all non-compliant drones to be removed from federally supported activities by December 22, 2025. To remain eligible for funding, researchers should begin reviewing their drone inventories and transitioning to approved systems.
... I don't know the specific grant I have.
We recommend discussing your grant with OSPRI. We can not lead you in the right direction unless we know where your grant is coming from and if there are any exceptions included in your grant.