- The Department of War has launched a Section 805 compliance website
- The site explains procurement restrictions, timelines and waiver process
- The Potomac Officers Club will host two DOW summits this summer
The Department of War has introduced a new website to help defense industry partners understand and comply with Section 805 of the Fiscal Year 2024 National Defense Authorization Act, which imposes procurement restrictions involving entities identified on the Section 1260H list of Chinese military companies.
As defense acquisition policies and industrial base requirements continue to evolve, government and industry leaders will have opportunities to discuss broader modernization priorities at the Potomac Officers Club’s DOW summits this summer. Register now for the 2026 Air and Space Summit on July 30 to hear discussions on commercial space relay, optical networks, artificial intelligence and other emerging defense technologies. You can also save your seat today for the 2026 Navy Summit on Aug. 27 to join maritime leaders examining naval modernization, autonomous systems and next-generation capabilities.
What Does the DOW Website Offer to Defense Industry Partners?
Managed by the Office of the Assistant Secretary of War for Industrial Base Policy, DOW said Tuesday the website serves as a centralized resource for implementing Section 805 of the FY24 NDAA. It outlines procurement restrictions, explains the implementation timeline, provides compliance guidance and details the waiver process for companies that need additional time to transition away from suppliers on the Section 1260H list.
The Entity Prohibition, or “direct” ban, took effect Tuesday, June 30, prohibiting the department from procuring from companies identified as Chinese military companies under Section 1260H, including entities under their control.
The Goods and Services Prohibition, or “indirect” ban, will take effect on June 30, 2027. Beginning on that date, the department will be prohibited from entering into, renewing or extending contracts for the procurement of goods or services incorporating products or services produced or developed by Section 1260H-listed companies or entities they control.
The website also provides contact information for DOW’s Section 805 team to assist companies with implementation questions.
What Documents Does the Department Require for Waiver Requests?
DOW said companies seeking additional time to transition away from suppliers on the Section 1260H list may submit waiver requests if they can demonstrate that the request is in the U.S. national interest.
Complete waiver requests must include:
- A completed waiver request form
- A cover letter
- A compelling justification narrative and market analysis addressing mission criticality, programmatic impact and the lack of a mature market
- A detailed entity phase-out plan outlining specific corporate actions, milestones, dedicated resources and timelines
Applicants may also submit supplemental documentation, including charts, technical specifications or supplier data, to support their requests.
What Is Section 851 of the FY 2025 NDAA?
The launch of the Section 805 website comes as additional procurement restrictions involving Chinese military-linked companies have taken effect.
According to Federal News Network, Section 851 of the FY 2025 NDAA prohibits DOW from entering into contracts with companies that retain “covered lobbyists” who engage in lobbying activities on behalf of companies designated as Chinese military companies under the Section 1260H list.
The provision, which took effect Tuesday, bars the department from entering into contracts with companies that retain those lobbyists. Federal News Network reported that the requirement effectively forces lobbying and consulting firms to choose between representing certain Chinese military-linked companies and maintaining business with DOW contractors.
