In November 2022, the FCC published an Order placing restrictions on future product authorizations for companies producing equipment on the Covered List, including Dahua Technology USA Inc. (“Dahua”). As part of the Order, the FCC created a pathway for certain Covered List companies, including Dahua, to secure future authorizations for telecommunications and video surveillance equipment, provided these entities can demonstrate that their products are not being marketed or sold for public safety, security of government facilities, physical surveillance of critical infrastructure or other national security purposes.
As the next step in the process, on April 7, 2023, Dahua submitted a Compliance Plan to the FCC: https://www.fcc.gov/ecfs/document/10407306916954/1. This plan outlines concrete steps and procedures to ensure Dahua products are not marketed or sold for national security purposes.
By taking a holistic approach to our operations, this compliance plan represents a substantive step forward to ensure Dahua can continue to meet the needs of distributors, dealers, and end-users in the US marketplace for years to come.
The compliance plan addresses the following categories:
- Personnel
- Labeling and packaging requirements
- Marketing and sales requirements
- Training
- Record-keeping
- Contract requirements
- Existing customers
- Handling violations and corrective actions
- Monitoring and auditing
- Reporting obligations
For each category, we present how Dahua will monitor and enforce review processes and compliance measures to address FCC concerns around national security. We believe our comprehensive plan presents an effective framework for Dahua to remain in compliance with the restrictions outlined in the November 25, 2022 FCC Order.
In the weeks ahead, we expect the FCC to conduct a thorough review of the proposed plan. Our hope is that the FCC will return substantive feedback, and that we can continue to engage with the Commission to pave a workable path forward for Dahua to receive future product authorizations.
To read more about our previous engagement with the FCC and the November, 25 2022 FCC Order, please see our blog, which includes an overview of the FCC rulemaking process, as well as a memorandum on the FCC Order.