Cite as. Gatewell Group, Regime Profiles to the Gatewell Protocol for Origin Evidence, General Provisions (Public comment draft, Revision 1, September 17, 2026), https://gatewellgroup.com/protocol/profiles/. Cite a clause by its number, which is its anchor: https://gatewellgroup.com/protocol/profiles/#p.1.1.
Conformity with a profile is a documentation standard. It is not a determination by any contracting officer, awarding agency or other government body that an item complies with the governing instrument, and it guarantees no procurement, award or audit outcome. This document is not legal advice.
Part PGeneral provisions
P.1 Purpose
P.1.1 The Protocol defines the Origin Evidence File ("OEF") for connected equipment in categories subject to the FCC Covered List. Other federal regimes put the same three questions to a product or a material: who owns its maker, where it was made, and what evidences the answer. A profile applies the OEF to one such regime, so that a contracting officer, prime contractor, pass-through entity, auditor or commercial counterparty examining the file can trace every origin claim to an identified source document.
P.1.2 The profiles published with these provisions are Profile DM (defense covered materials), Profile DB (defense batteries), Profile DU (defense and federal unmanned aircraft systems), Profile S889 (Section 889 covered telecommunications equipment) and Profile BA (Build America, Buy America manufactured products).
P.2 Relationship to the Protocol
P.2.1 A profile incorporates by reference Parts II, III, V, VI and VII of the Protocol, Version 1.0, together with the clauses of Part IV and the Annexes that its application table (section 4 of each profile) names.
P.2.2 A profile prescribes evidence and procedure only. It sets no ownership, content-percentage or origin threshold of its own. Every outcome standard, including whether an item is restricted, whether an exception applies and what percentage or process step decides origin, is incorporated by reference from the governing instrument as in force on the file's revision date.
P.2.3 A profile does not alter any clause of the Protocol for a file assembled under the Protocol alone.
P.2.4 One file may serve the Protocol and one or more profiles. Where it does, the clause 4.1.3 schedule SHALL state, per item, which sections and document IDs evidence which regime.
P.2.5 Where a profile and its governing instrument differ, the instrument governs. A profile yields to any mandatory documentation standard on that standard's effective date.
P.3 Structure of a profile
Every profile is organized in nine sections, numbered with the profile's designation: (1) scope and governing instruments; (2) the governing test, quoted, informative; (3) applicability determination; (4) application of the Origin Evidence File; (5) additional evidence; (6) entity screen; (7) records and schemas; (8) claims of conformity; (9) limits of the profile and questions for comment.
P.4 Conformance language
Clause 1.3 of the Protocol applies. Numbered statements are requirements. Material marked informative, including every quotation from a statute, regulation, clause or guidance document, is provided for convenience and does not add or alter requirements. Where a quotation and its source differ, the source governs.
P.5 Currency of governing instruments
P.5.1 The governing instruments named in section 1 of a profile SHALL be re-retrieved at each revision date of the file, and the retrieval evidenced, in the manner of clause 4.2.2.
P.5.2 In addition to the Part VI triggers, each of the following is a material change under a profile: an amendment, deviation, waiver, determination or effective-date event under a governing instrument that touches an item, material, entity or exception in the file.
P.6 Claims of conformity
P.6.1 Conforming parties may state: "[Company]'s Origin Evidence File for [items] conforms to the Gatewell Protocol for Origin Evidence, Version 1.0, Profile [designation], at Level [1/2/3], as of [date]."
P.6.2 A claim SHALL name the profile, the level and the date, SHALL NOT extend to items outside the schedule, and SHALL NOT state or imply that any government body has reviewed, accepted or endorsed the file.
P.6.3 A claim of conformity to a profile is a statement about the file. It is not a determination that an item complies with the governing instrument, and it is not a representation, certification or legal opinion under that instrument.
P.7 Status and comment
These provisions and the profiles are published as a public comment draft under the terms of Part VII of the Protocol. Comments are received in the Protocol's comment docket through October 31, 2026. Verification under a profile opens with its final text.
P.8 Pending instruments (informative)
A profile is written to an instrument in force. Section 163 of H.R. 8800, the House-passed National Defense Authorization Act for Fiscal Year 2027, would bar the Secretary of Defense from procuring a covered humanoid robotic system produced, developed or controlled by a foreign adversary. It had not been enacted as of September 17, 2026, and the Senate bill as reported contains no counterpart. Advanced robotic devices are a Protocol category, and clauses 4.3 through 4.6 already call for the production, ownership, software, model-weight and update-authority evidence the section's text turns on. A profile follows enactment.
ProfilesThe profiles in this draft
| Profile | Regime | Governing instruments |
|---|---|---|
| Profile DM | Defense covered materials | 10 U.S.C. 4872, text in effect September 16, 2026; DFARS subpart 225.7018 (policy), DFARS Change 5/7/2026, effective May 7, 2026; DFARS clause 252.225-7052, Restriction on Acquisition of Certain Magnets, Tantalum, and Tungsten (MAY 2024); Class Deviation 2026-O0041, Revision 1, July 1, 2026, Attachment A1, including clause 252.225-7961 (JUN 2026) and the accompanying PGI text; DFARS PGI 225.7018-3 and PGI 225.7018-4; DFARS 225.7003-1, definitions of high performance magnet and electronic component; Pub. L. 119-60 (FY26 NDAA), sections 844 and 848, approved December 18, 2025; Executive Order 14415, Securing America's Defense Supply Chains and Ensuring Domestic Acquisition of Critical Materials, July 20, 2026, 91 FR 46693, section 2 |
| Profile DB | Defense batteries | National Defense Authorization Act for Fiscal Year 2024, section 154: Pub. L. 118-31, div. A, title I, subtitle E, § 154, 137 Stat. 180-181; 10 U.S.C. note prec. 4651. Enrolled text, retrieved September 2, 2026; National Defense Authorization Act for Fiscal Year 2026, section 842: Pub. L. 119-60, div. A, title VIII, § 842, 139 Stat. 974-975, adding 10 U.S.C. 4865. Approved December 18, 2025; retrieved September 2, 2026; Prohibition on acquisition of advanced batteries composed of materials from certain foreign sources: 10 U.S.C. 4865. As added by Pub. L. 119-60 § 842; retrieved September 2, 2026; Foreign entity of concern, definition incorporated by 10 U.S.C. 4865(e)(4): Infrastructure Investment and Jobs Act § 40207(a), 42 U.S.C. 18741(a)(5). Current text, retrieved September 2, 2026; Prohibited foreign entity, definition naming the section 154 entities: 26 U.S.C. 7701(a)(51)(B)(iv). Current text, retrieved September 2, 2026; relevant to this profile for the entity screen only |
| Profile DU | Defense and federal UAS | FY20 NDAA section 848: Pub. L. 116-92, div. A, title VIII, § 848, 133 Stat. 1508 (December 20, 2019), as amended by Pub. L. 117-263, div. A, title VIII, § 817(a), 136 Stat. 2707 (December 23, 2022), set out as a note under 10 U.S.C. 4871; text as printed; American Security Drone Act of 2023: Pub. L. 118-31, div. A, title XVIII, subtitle B, §§ 1821 to 1833, 137 Stat. 691 et seq., approved December 22, 2023; Federal Acquisition Regulation subpart 40.2: 48 CFR 40.201, 40.202 (current edition); FAR clause 52.240-1, Prohibition on Unmanned Aircraft Systems Manufactured or Assembled by American Security Drone Act-Covered Foreign Entities (Nov 2024); FY25 NDAA section 1709: Pub. L. 118-159, div. A, title XVII, § 1709, 138 Stat. 2214 to 2216, approved December 23, 2024; 49 U.S.C. 44801(11), (12) (United States Code, 2023 edition) |
| Profile S889 | Section 889 | John S. McCain National Defense Authorization Act for Fiscal Year 2019, Pub. L. 115-232, div. A, title VIII, § 889, 132 Stat. 1917-1919 (enacted August 13, 2018); FAR subpart 4.21, 48 CFR 4.2100 through 4.2105, text in force September 15, 2026; FAR clause 48 CFR 52.204-25, clause date NOV 2021, text in force September 15, 2026; FAR provision 48 CFR 52.204-24, clause date NOV 2021; FAR provision 48 CFR 52.204-26, clause date OCT 2020; FAR provision 48 CFR 52.212-3(v), commercial products and commercial services offeror representations; 2 CFR 200.216, text in force September 15, 2026; 2 CFR 200.471, telecommunications and video surveillance costs; 2 CFR 200.1 and 2 CFR 200.101, definitions and applicability |
| Profile BA | Build America, Buy America | Build America, Buy America Act, Infrastructure Investment and Jobs Act, Pub. L. 117-58, div. G, title IX, §§ 70901 through 70927; 2 CFR part 184, Buy America Preferences for Infrastructure Projects (eCFR text current through September 15, 2026); OMB Memorandum M-24-02, Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure (October 25, 2023); 2 CFR 200.317, 200.319, 200.332 and 200.339 (eCFR text current through September 15, 2026); 23 CFR 635.410 (eCFR text current through September 15, 2026); NTIA, Build America, Buy America Compliance and Documentation Requirements and Procedures (edition bearing PDF creation date October 21, 2025); 48 CFR 25.003 and 48 CFR 25.101 (eCFR text current through September 15, 2026), for the comparison at BA.2.5 only |
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