The Gift that Keeps on Giving: FAR Council Attempts to Reduce Burden of Representation Requirement for Covered Telecommunication Offerings
Client Alert | 1 min read | 12.16.19
Following an August 2019 interim rule that implemented a ban on government procurement of any equipment, system, or service that uses covered telecommunications equipment or services (CTES) from certain Chinese companies including Huawei and ZTE, effective December 13, 2019, the FAR Council issued a second interim rule authorizing companies to annually represent whether they provide CTES to the Government in the System for Award Management (SAM) registration. This new provision at FAR 52.204-26 would allow offerors to avoid the offer-by-offer representation requirement in FAR 52.204-24 (currently required under the first interim rule).
FAR 52.204-26 applies to all acquisitions, including simplified and commercial item acquisitions, and requires companies to review SAM and validate whether any products or services originate from CTES prior to completing their required representations. To facilitate compliance, the Government will update SAM to list the Chinese companies that provide CTES and annotate where prohibitions are limited to select products and services instead of the entire company.
Contacts

Partner and Crowell Global Advisors Senior Director
- Washington, D.C.
- D | +1.202.624.2698
- Washington, D.C. (CGA)
- D | +1 202.624.2500
Insights
Client Alert | 2 min read | 10.23.26
One of the two landmark climate-disclosure laws California enacted in 2023 has its first reporting deadline in just over two weeks, amid continued uncertainty regarding its constitutionality.
Client Alert | 7 min read | 10.22.26
Africa, MENA, and the Arbitration Act 2025: LCIA’s Latest Report
Client Alert | 4 min read | 10.22.26
CMS Proposal Would Require Extensive Provider Directory Changes in MA
Client Alert | 5 min read | 10.22.26
CMS Proposes Major Changes to MA, Part D, and PBM Requirements



