Pentagon Tightens Rules on Foreign-Made Circuit Boards
Published Date: 7/2/2026
Proposed Rule
Summary
The Department of Defense is updating rules about buying printed circuit boards to keep our supply chain safe from certain countries. This change affects companies selling these boards to the DoD and aims to stop purchases from restricted nations. If you’re involved, get ready to share your thoughts by August 31, 2026, as this could impact future contracts and spending.
Analyzed Economic Effects
6 provisions identified: 0 benefits, 6 costs, 0 mixed.
Ban on PCBs from Covered Nations
If you sell printed circuit boards (PCBs) to the Department of Defense, DoD proposes prohibiting procurement of covered PCBs from entities located in or controlled by the People's Republic of China, the Russian Federation, the Islamic Republic of Iran, and the Democratic People's Republic of North Korea under 10 U.S.C. 4873. This would block sourcing PCBs made or partially made in those covered nations unless a statutory exception or waiver is granted.
New Certification Conditions for Waivers
DoD proposes that contractors seeking waivers to source covered PCBs from a covered nation must demonstrate compliance with an Independent Hardware Assurance Framework that includes ISO/IEC 20243 (O-TTPS), IPC-1782 traceability (Level 3 or 4), and IPC-1791 facility requirements. Contractors must hold formal, third-party ISO/IEC 20243 and IPC-1791 certifications and produce IPC-1782 traceability data; mere internal attestations will not satisfy the framework.
Mandatory Flow‑Down Across All Supply Tiers
Any DFARS clause resulting from this rule would require contractors to flow down its substance into all subcontracts at every tier, including commercial product and service subcontracts, and retain ultimate responsibility for collecting and verifying third‑party certifications (ISO/IEC 20243, IPC-1791) and IPC-1782 traceability from lower-tier suppliers. Flow-down exceptions apply for designated DoD Hardware Assurance Laboratories, FFRDCs, UARCs, and similar entities.
Estimated Certification Timelines
DoD estimates IPC-1791 certification requires 8 to 16 months, while IPC-1782 and ISO/IEC 20243 require about 3 to 11 months. DoD is asking whether phase-in periods such as 12, 18, or 24 months should be considered before making these standards mandatory.
Data Delivery, Access, and 10‑Year Retention
Contractors would be required to deliver IPC-1782 manufacturing traceability logs and IPC-1791 hardware assurance test reports in a standardized, machine-readable format within a specified timeframe (example: five business days) upon Government request. Contractors and verification facilities must retain verification imagery and traceability logs for at least 10 years after final delivery or for the operational lifespan of the defense system, whichever is longer, and grant Government audit access.
Independent Verification and DoD Lab Validation
For any bare PCB manufactured or partially manufactured in a covered nation, waiver requests must include a certified verification report from a domestic or allied IPC-1791 Trusted Assembler showing blind testing. If the Trusted Assembler is affiliated with the contractor, verification reports, imagery, design files, and/or hardware must be submitted to a DoD Hardware Assurance Lab (or designated entities such as NSA, DOE National Laboratories, FFRDCs, or UARCs) for independent validation before the component head submits the waiver to the Secretary of Defense.
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Key Dates
Department and Agencies
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