VIEWPOINT: NDAA Continues Trend of Supply Chain Vigilance to Reduce Reliance on China

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Section 868 would require the comptroller general of the United States to conduct a study identifying the Defense Department’s dependence on foreign entities for certain end items and components, including the extent to which its procurement processes permit determining the country of origin of end items and components. However, the domestic content requirement would not apply to countries that are members of the national technology and industrial base: Australia, Canada, New Zealand, and the United Kingdom. Additionally, the domestic content requirement would exclude articles manufactured in countries that have executed a reciprocal defense procurement memorandum of understanding with the United States, such as certain European and NATO allies, Egypt, Israel and Japan. Companies who do not possess the capability to identify and assess foreign ownership, control or influence concerns within supply chains or potential options for mitigations may need to turn to outside experts to understand how to remain in compliance with the Defense Department and other U.S. regulations. She served as the special advisor to the assistant secretary of export administration and as acting chief of staff of the Bureau of Industry and Security at the Department of Commerce.

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