Prohibited Equipment Message

Federal prohibition on certain telecommunications and video equipment

The purchase and use of telecommunications and video equipment is allowed, in general. However, Mines may not purchase or use telecommunications or video equipment made by certain manufacturers. Colorado School of Mines personnel may not use electronic equipment in university systems if the equipment is manufactured by the following prohibited companies:

Huawei Technologies Company
ZTE Corporation
Hytera Communications Corporation
Hangzhou Hikvision Digital Technology Company
Dahua Technology Company
Or any subsidiary or affiliate

If you have any questions or happen to have acquired “covered telecommunications equipment or services” from any of these companies, or are aware that covered phones or equipment is being used as a component of a University electronic system, please contact Scot Allen in Research & Tech Transfer, exportcontrols@mines.edu or Natalie Vega, Executive Director of Compliance, Policy & Risk Management, at nvega@mines.edu.

Discussion.

Effective August 2020, federal government agencies may no longer contract with universities, companies, and other organizations that make use of certain telecommunications or video equipment manufactured by specific companies that Congress has determined present a risk to secure communications. So, Mines could lose federal grants and contracts if we use prohibited equipment, whether we purchased it or received it in kind or as part of a gift or donation.

The phrase “covered telecommunications equipment or services” is defined by law to encompass—

  1. Telecommunications equipment produced by—
    1. Huawei Technologies Company,
    2. ZTE Corporation, or
    3. any subsidiary or affiliate;
  2. Video surveillance and telecommunications equipment produced by—
    1. Hytera Communications Corporation,
    2. Hangzhou Hikvision Digital Technology Company,
    3. Dahua Technology Company,
    4. or any subsidiary or affiliate; and
  3. Telecommunications or video surveillance services provided by such entities or using such equipment.

If you have any questions, please contact Natalie Vega or Scot Allen (info above). Thank you in advance for your attention to this matter.

Reference: The relevant prohibition appears in the National Defense Authorization Act for FY 2019, Pub. L. No. 115-232 (NDAA). Specifically, Section 889 of the NDAA restricts the use of “covered telecommunications equipment or services.” Such equipment or services must not be used “as a substantial or essential component of any system, or as a critical technology as part of any system.”

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