By Dennis Blacksmith One of the most important — and often misunderstood — aspects of the new DFARS 252.225-7052 rules is how integration affects commercial off-the-shelf (COTS) components. Many companies assume that if the hardware is COTS, it remains exempt from the new tracing requirements. The reality is more nuanced. When you take commercial hardware — such as computers, displays, VR headsets, tablets, or edge devices — and combine it with purpose-built training software

By Dennis Blacksmith One of the most dangerous misconceptions in defense supply chain compliance is the assumption that commercial off-the-shelf (COTS) items remain exempt from the new rules. The updated DFARS 252.225-7052 and NDAA Section 842 requirements are changing that reality. The regulation is clear that COTS items lose their exception once they are incorporated into a defense end item. This includes training simulators, VR/AR systems, instructor stations, and any othe