Attachment 1 U.S. Customs and Border Protection

Sole Source Determination For Actions Not Exceeding the SAT

March 2026

Date: ___09/23/2026____ PR Number: __20157040___

1. Identification of the agency and the contracting activity:

The U.S. Department of Homeland Security, U.S. Customs and Border Protection, Office of Acquisition proposes to enter into a contract on a basis other than full and open competition using simplified procedures in accordance with Federal Acquisition Regulation (FAR) 12.201-1, FAR Class Deviation 25-21 R1 for FAR Part 12, and 41 U.S.C. 1901.1

2. Nature and/or description of the item/service being procured and anticipated cost:

The CBP Office of Professional Responsibility, Security Management Division (SMD) has a requirement, on a sole source basis, for a firm fixed price Purchase Order to acquire High- Security Holographic Overlay Laminate Pouch Sets for all issued CBP credentials.

The anticipated cost is $

3. Authority to award a sole source order:2

_________ RFO Subpart 8.4/GSAR 538.7104-3(a) ___X______ RFO 12.102(a) _________ RFO 13.101(b)

_________ RFO 16.507-6

4. Sole Source Determination Rationale: (Check one and explain below):

For RFO Subpart 8.4, Part 12 and Part 13 procurements, check one of the following:

___X______ Only one source reasonably available.

_________ Urgent and compelling circumstances exist.

_________ Exclusive licensing agreement exists.

1 In this document, citations to RFO Parts 5, 10, 12, and 25 are citations specifically to FAR Class Deviation 25-17 for FAR Part 5, FAR Class Deviation 25-06 for FAR Part 10, FAR Class Deviation 25-21 R1 for FAR Part 12, and FAR Class Deviation 26-09 R1 for FAR Part 25, which were issued as part of the Revolutionary FAR Overhaul (RFO), implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

2 In this document, citations to RFO Parts 8, 12, 13, and 16 are citations specifically to Federal Acquisition Regulation (FAR) Class Deviation 25-20 for FAR Part 8, FAR Class Deviation 25-21 R1 for FAR Part 12, FAR Class Deviation 26-01 R1 for FAR Part 13, and FAR Class Deviation 26-04 R1 for FAR Part 16, which were issued as part of the Revolutionary FAR Overhaul (RFO), which was implemented in response to Executive Order 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025.

Sole Source Determination For Actions Not Exceeding the SAT

March 2026

_________ Item peculiar to one manufacturer. If this requirement applies to a portion of the procurement, please identify that portion.

_________ Industrial Mobilization _________ Other. Explain:

Explanation of the rationale cited:

OPSEC SECURITY INC is the only Laminate manufacturer capable of providing High-Security Holographic Credential Laminate that maintains 100% consistency with the laminate used for previously issued/existing CBP/DHS credentials and newly issued CBP/DHS credentials.

All DHS Components utilize a standardized credential design and anti-counterfeiting laminate material that is specifically designed for DHS components and produced solely by OPSEC SECURITY, INC., 185 Colonial Village Lane, Lancaster PA 17601. UEI# Y1KQH3MMQPW5.

This vendor is capable of scaling production to meet CBP/DHS needs. OPSEC is able to provide the high-security holographic laminate with quick turn-around times, allowing the Government to avoid incurring substantial costs associated with unacceptable delays to credential production and issuance to employees. Delay of credential issuance impacts an employee’s ability to perform CBP’s mission.

Further, design of a new credential laminate would result in additional costs and unacceptable security risks to the Government. Not only would there be duplicative design costs, but DHS and its component agencies would be required to collect, destroy, and re-issue all credentials currently in use in order to ensure 100% consistency among all credentials. This is a security measure to prevent fraud and misuse of credentials. It is not in the best interest of the Government to incur additional costs for a new design or the elevated operational security risks that would occur by permitting different types of laminate to be used for new credentials. This increases the likelihood that counterfeit credentials may be used. Law Enforcement personnel depend on the ability to trust that a CBP credential is valid when one is presented.

A notice of intent to sole source was posted for this requirement on SAM on September 4, 2026.

Responses were due by September 11, 2026. On September 8, 2026, one (1) interested vendor, responded, but they were determined by the program office to be incapable because of the following reasons:

a. Lack of Proprietary Design and Security Features:

The required laminate is a proprietary, high-security product specifically engineered for DHS/CBP. It contains unique, embedded security features (holograms, seal inlays, and specific DHS branding) that are protected under DHS branding requirements.

The vendor’s capability statement focuses on general identification products, labels, and access control solutions. It does not demonstrate the ability to replicate the specific, proprietary holographic security features required for DHS credentials.

Sole Source Determination For Actions Not Exceeding the SAT

March 2026

The vendor’s statement mentions "standard alternatives for laser materials" and "standard return policies," which confirms they are a general-purpose manufacturer rather than a specialized security laminate provider capable of meeting the stringent, proprietary specifications of this program.

b. Incompatibility with Existing Credential Infrastructure:

All DHS credentials currently in circulation must be 100% consistent in size, design, and tactile feel. Introducing a new vendor would result in a "differentiation in the visual appearance or feel" of the credentials.

This inconsistency would create significant security vulnerabilities, as security personnel (including TSA and other law enforcement agencies) rely on established, published credential formats to verify identity. A change in the laminate would call into question the validity of an employee’s authority when conducting official investigations or accessing secure areas.

c. Security and National Security Implications:

The design specifications for these laminate pouches are highly sensitive. Releasing these proprietary designs to an un-cleared, open-market vendors would create unnecessary security vulnerabilities and potentially compromise national security.

The vendor’s capability statement does not address the ability to handle or protect sensitive government security designs, nor does it demonstrate compliance with the specific security protocols required for DHS credentialing.

d. Logistical and Financial Burden of Transition:

Switching vendors would require the destruction of all existing credentials across all

DHS components to maintain absolute consistency. This would impose an unacceptable administrative and financial burden on the Government, estimated to exceed $450,000 for CBP alone, not including the costs for other DHS components.

All DHS components use identical high security holographic laminate for their credentials.

5. The anticipated price will be determined fair and reasonable based on one or more of the price analysis techniques described below.

____X_____ Market Research.

____X_____ Comparison of the proposed price with prices found reasonable on previous purchases.

____X_____ Current price List.

_________ Comparison with similar items in a related industry.