# Regime Profiles to the Gatewell Protocol for Origin Evidence

*Public comment draft, Revision 1 · September 17, 2026 · applies Protocol Version 1.0 (https://gatewellgroup.com/protocol/v1.0/) · CC BY 4.0 · https://gatewellgroup.com/protocol/profiles/*

## Part P. General 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.