The Department of Defense (DOD) is seeking industry input on revisions to acquisition regulations that would prohibit the department from buying printed circuit boards (PCBs) from certain foreign nations, according to an advance notice of proposed rulemaking posted to the Federal Register on July 2.
The proposed revision to the Defense Federal Acquisition Regulation Supplement (DFARS) would implement Section 841 of the fiscal year (FY) 2021 National Defense Authorization Act (NDAA) and section 851 of the FY 2022 NDAA.
The legislative provisions bar the Pentagon from buying PCBs from companies located in or controlled by adversarial nations, such as China, Russia, Iran, and North Korea.
“DOD intends to implement this prohibition by focusing on the geographic point of fabrication for bare boards or partially manufactured boards and by utilizing a tiered trust architecture,” the notice reads.
Any revisions to the DFARS would require DOD to establish trusted supply chain and operational security standards for the procurement of microelectronics and their associated PCBs.
Specifically, the Pentagon is seeking comment on an Independent Hardware Assurance Framework that would use ISO/IEC 20243, IPC-1782, and IPC-1791 as baseline requirements for exceptions and waivers. These stringent requirements would only be placed on covered PCBs being integrated into systems in which a compromise could directly threaten military mission, warfighter safety, or national security, according to the notice.
The notice said the approach is not a blanket prohibition on commercial products.
To obtain waivers, the notice said contractors would need to provide certifications, standardized, machine-level manufacturing traceability data, Trusted Assembler verification reports, market availability justifications, component details, system impact assessments, transition strategies, and waiver scope. Comments on the advance notice should be submitted before August 31.