The FAR Council issued an Advanced Notice of Proposed Rulemaking (ANPR) in early May that starts the ball rolling on a regulatory change to which all federal contractors must pay attention.  While the ANPR promulgates no new rules right now, its focus is on banning agencies from purchasing certain products or services that contain or otherwise utilize semiconductors that are produced, designed, or provided by three Chinese entities:  Manufacturing International Corporation (“SMIC”), ChangXin Memory Technologies (“CXMT”), and Yangtze Memory Technologies Corp. (“YMTC”).  The ANPR was issued in response to a provision requiring the ban included in the FY’23 Defense Authorization Act.  The issuance of an ANPR itself, is a sign to contractors that the Council expects this area to be one of significant controversy, and perhaps greatly increased industry costs.  Any proposed or final rule that comes from this process will cover “a semiconductor, a product incorporating a semiconductor, or a service that utilizes such a product that is designed, produced, or provided by” the three named entities or any foreign country of concern.  As with the Section 889 A&B telecommunications bans, the semiconductor ANPR envisions that contractors will be required to conduct a “reasonable inquiry” to detect and avoid the use or inclusion of covered semiconductor products or services in their supply chains.  In addition, however, the ANPR states that the FAR Council is also contemplating requiring offerors to identify the provenance of the supply chain for semiconductor components for each electronic product provided to the government, including identifying the vendors and facilities responsible for the design, fabrication, assembly, packaging, and test of the product, and (ii) manufacturer and distributor codes used for the product.   That could be a significant new information collection and maintenance requirement, especially for smaller firms.  Industry should weigh in with their thoughts on the ANPR by the July 2^nd comment due date.  Similarly, contractors should closely follow the rulemaking process at each step.  While implementation of the requirement isn’t scheduled until the end of 2027, the implications of this new regulation could bring substantial changes to contractor supply chains.  Getting on board now helps ensure being prepared later.