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NEW Federal Restrictions - Equipment, Services, and Collaborations

Summary - Action Required

What’s changed?  New federal research security requirements are restricting the use of goods and services from, or collaborations with, certain restricted entities in federally funded research.

  • The DoD Fundamental Research Decision Matrix prohibits the use of DoD funds for fundamental research conducted in collaboration with, or using equipment from, entities appearing on DoD Prohibited Entity Lists. Of the current 13 prohibited lists the two main ones include the DoD1260H List and DoD1286 List.
  • NSF announced on July 8, 2026, its intent to implement in Fiscal Year 2027 a new policy prohibiting (1) use of NSF funds on collaborations with entities on certain U.S. restricted parties lists, and (2) senior/key personnel on NSF-funded projects from holding an appointment or position with, or receiving research support from, these restricted entities for the duration of their NSF award. Although the policy is scheduled for full implementation in FY2027, NSF has already begun incorporating these restrictions into certain award and proposal review processes.
  • The BIOSECURE Act, enacted on December 18, 2025, will phase restrictions that prevent federal funding recipients from using biotechnology equipment or services from “biotechnology companies of concern” in in the performance of federal contracts or grants.
  • For a list of other prohibitions on equipment, software, or services that are already in effect, see the FAQ below titled “What other equipment terms and conditions should you be aware of and make sure to follow?”

We understand that this is a complex topic. If you have any questions, please reach out to the Export Controls & International Compliance team for assistance.

What do I need to do?

  • Researchers with DoD funding must immediately identify and cease any collaborations with, or use of equipment from, entities on DoD Prohibited Entity Lists in DoD-funded projects. Additionally, do not make any new purchases from, or enter into any new collaborations with, any of those entities.
  • Researchers funded by other federal agencies should begin preparing for future restrictions.
    • NSF: Researchers who have or expect to apply for NSF funding should review the Dear Colleague Letter their collaborations for relationships with entities on the U.S. restricted parties lists. Although the policy is scheduled for full implementation in FY2027, NSF has already begun incorporating these restrictions into certain award and proposal review processes.
    • Other federal funding: Researchers who have or expect to apply for other federal funding should plan ahead by reviewing and identifying alternatives to equipment, services, software, and collaborations from or with entities on DoD Prohibited Entity Lists. and other U.S. restricted parties lists, particularly biotechnology equipment and services ahead of implementation of the BIOSECURE Act. 
  • For activities not funded by federal agencies, procurement of equipment or services from restricted parties can be considered if no viable or cost-effective alternative exists. Discuss these purchases in advance with your school leadership and the Export Controls & International Compliance (ECIC) team. However, equipment and services from restricted entities should not be purchased for use in spaces where federally funded research may take place, such as core facilities, recharge centers, and other shared facilities and resources on campus.

Background Information on Regulations 

DOD:  The DoD Fundamental Research Decision Matrix prohibits the use of DoD funds for fundamental research conducted in collaboration with, or using equipment from, entities appearing on DoD Prohibited Entity Lists. The restriction applies not only to new purchases but also to equipment already owned and used on DoD-funded projects, requiring researchers to stop using this equipment or work with DOD to develop transition or mitigation plans. Additional research security restrictions apply to collaborations (even co-authorship) with Prohibited Entities, foreign funding from countries of concern, and participation in malign foreign talent recruitment programs.

NSF:  NSF announced on July 8, 2026, its intent to implement in Fiscal Year 2027 a new policy prohibiting (1) use of NSF funds on collaborations with entities on certain U.S. restricted parties lists, lists, and (2) senior/key personnel on NSF-funded projects from holding an appointment or position with, or receiving research support from, these restricted entities for the duration of their NSF award. Although the policy is scheduled for full implementation in FY2027, NSF has already begun incorporating these restrictions into certain award and proposal review processes.

Other Agencies: While other major federal research funding agencies, such as NSF, NIH, DOE, and USDA have implemented similar risk review processes and/or rely on U.S. restricted party lists (including the 1260H list) to assess international affiliations and collaborations, they have not yet imposed prohibitions—like those of the DoD—on the use of equipment from listed entities.

However, the BIOSECURE Act, enacted on December 18, 2025, does broadly restrict procurement involving biotechnology products or services over the course of several years. While not effective in the immediate-term, under this Act, federal agencies and entities that receive federal funds cannot “procure or obtain any biotechnology equipment or service produced or provided by a biotechnology company of concern,” (BCC) and agencies and grantees are also prohibited from entering, extending, or renewing a contract with an entity that uses equipment or services provided by a BCC. 

Entities are automatically designated as a BCC through inclusion on the 1260H list. In addition, the Office of Management and Budget has been directed to determine which additional entities should be classified as BCCs by December 18, 2026, and to publish a list annually. The prohibition is anticipated to become effective in Summer/Fall 2028. What is not known is whether individual federal agencies will, like DoD, implement their own prohibitions on equipment from 1260H listed entities in advance of BIOSECURE Act implementation.

FAQs - Equipment Purchases and Restricted Party Screenings

DoD Principal Investigators (PIs) must ensure that any equipment they plan to use is not sourced from or manufactured by an entity listed on a Prohibited Entity List. Because multiple such lists exist, Northwestern subscribes to a third-party tool, Visual Compliance, that consolidates and maintains up-to-date versions of these lists. As the lists change over time, the most effective way to remain compliant is to use the Visual Compliance screening tool to conduct restricted party screenings. Of the current 13 prohibited lists the two main ones include the DoD1260H List and DoD1286 List.

Who is responsible for screening compliance?

The Principal Investigators (PI) are ultimately responsible for ensuring that:

  • No purchases are made from restricted parties
  • No equipment or items are obtained from restricted parties
  • No items sourced from restricted parties are being used for their federally funded research
  • Restricted parties are not providing services to the work of their group
This responsibility applies regardless of the purchasing method, including P-card transactions.

How do I conduct a restricted party screening?

Most vendor purchases are automatically screened if they go through Northwestern’s Procurement, Payment & Logistics Vendor Setup system managed by Purchasing. For other cases, like purchases with a P-card, you can:

  • To get access to Visual Compliance screening tool, contact the ECIC team.

Note: Due to review/screening volume, obtaining your own access to the tool is generally the most efficient option. We are also working on developing a simple website lookup tool that consolidates all the various lists and hope to share that resource in the near future.

Are all purchases automatically screened?

No, not all purchases are automatically screened. Purchases processed through Northwestern’s Procurement, Payment & Logistics’ Vendor Setup system are automatically screened. However, purchases made using a P-card (procurement card) are not automatically screened. If you are using a P-card, you are responsible for ensuring that appropriate screening is completed.

Do I need to screen all purchases used in my research?

Ideally, yes. We recognize that screening every purchase is not always feasible. Researchers are advised to focus screening efforts on items associated with critical or sensitive technologies and higher‑risk purchases rather than low‑risk, routine items such as common laboratory or office supplies that are readily available through standard commercial vendors.

Which purchases should be prioritized for screening?

Ideally, all DoD-funded purchases should be screened. Screening should be prioritized for higher‑risk equipment and technologies, particularly those that may be relevant to export controls, national security concerns, or specialized equipment or computing software. Routine, low‑risk items (general lab equipment) may not require the same level of review.

What items are considered lower risk?

Lower‑risk items typically include commercially available laboratory equipment and consumables that are widely used for routine research and teaching and do not have inherent military, intelligence, or dual‑use sensitivity.   However, many biological and chemical reagents and tools have dual-use status.

Are there specific suppliers or lists I should be aware of?

Yes. The DoD emphasized the importance of avoiding purchases from entities on the DoD1260H List and the DoD1286 List.  When feasible, higher‑risk purchases should be screened against all applicable restricted or prohibited party or entity lists, consistent with University policy and federal requirements of not purchasing or using equipment from Prohibited Entities or parties. Note:  Northwestern’s restricted party screening tool has a consolidated list of these restricted party lists.

Does this guidance apply to past purchases?

Yes. Please flag any past purchases from Prohibited Entities and do not use them in DoD projects. Notify the exportcontrols@northwestern.edu if you identify any impacted equipment or services and they will assist with next steps in coordination with the PI and Department Leadership. The Office for Research is also researching past purchases and agreements through the Procurement Department and Sponsored Research.

What other equipment terms and conditions should you be aware of and make sure to follow?

Each federal agency’s guidance, awards and agreements differ, and you need to ensure that you follow the terms and conditions. Some of the restrictions include but are not limited to the following:

  • BIOSECURE ACT: Section 851 of the NDAA.
  • Prohibition on Contracting for Hardware, Software, and Services Developed or Provided by Kaspersky Lab Covered Entities FAR 52.204-23
  • Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services or Equipment FAR 52.204-25
  • Prohibition on Unmanned Aircraft Systems Manufactured or Assembled by American Security Drone Act-Covered Foreign Entities FAR 52.240-1 Reference this resource related to Drone purchases.
  • National Security and Unallowable Costs - USDA Terms and Conditions though we expect other agencies have or will adopt similar terms

Who can I contact with questions about this guidance?

If you have questions about screening requirements, high‑risk technologies, or whether a planned purchase may require review, please contact Northwestern’s Export Controls & International Compliance team.

Resources Related to Collaborations including Co-Authorship

We have published several other related guidance over the last several months. Please see the below for additional resources, particularly for screening collaborators to ensure you are not collaborating with a restricted or prohibited party.