SSJ LightLab3LE CannabisAnalyzers Signed_Redacted.pdf

Attachment 1 U.S. Customs and Border Protection

Sole Source Determination For Actions Not Exceeding the SAT

March 2026

Date: September 16, 2026_ PR Number: 20156322______________

1. Identification of the agency and the contracting activity:

Department of Homeland Security (DHS), U.S. Customs and Border Protection (CBP), Laboratories and Scientific Services (LSS), Houston Laboratory.

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

The Government intends to procure two (2) LightLab 3 LE High Sensitivity Cannabis Analyzers from Orange Photonics. The acquisition includes required accessories, consumables for 100 two-scans/analyses, inside delivery, setup, initial software configuration, in-person training, and a year extended warranty for each analyzer.

Anticipated Cost:

3. Authority to award a sole source order:1

(Check the authority below based on the procurement procedures being followed)

_________ 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:

_________ Only one source reasonably available.

_________ Urgent and compelling circumstances exist.

_________ Exclusive licensing agreement exists.

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

_________ Industrial Mobilization

1 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

___ X_____ Other. Explain:

For RFO Subpart 16.5 procurements, refer to the exceptions to fair opportunity at RFO 16.507- 6(b) and check one of the following:

_________ The agency need for the supplies or services is so urgent that providing a fair opportunity would result in unacceptable delays.

_________ Only one awardee is capable of providing the supplies or services required at the level of quality required because the supplies or services ordered are unique or highly specialized.

_________ The order must be issued on a sole-source basis in the interest of economy and efficiency because it is a logical follow-on to an order already issued under the contract, provided that all awardees were given a fair opportunity to be considered for the original order. If the contracting officer uses the logical follow-on exception, the rationale must describe why the relationship between the initial order and the follow-on is logical (e.g., in terms of scope, period of performance, or value).

________ It is necessary to place an order to satisfy a minimum guarantee.

________ Item peculiar to one manufacturer. If this justification applies to a portion of the procurement, please identify that portion. For an order in excess of $40,000, CBP intends to provide this justification and supporting documentation along with the solicitation to all contract awardees pursuant to RFO 16.507-7(c). (*Rename this document a “Justification for Brand Name Exception to Fair Opportunity” if RFO 16.507-7 applies.)

Explanation of the rationale cited:

Market research confirms that the Orange Photonics LightLab 3 LE High Sensitivity Cannabis

Analyzer is the only identified system that meets all CBP minimum requirements stated in the SOW. CBP requires portable cannabis analyzers capable of rapidly detecting required cannabinoids, determining relative dry weight amounts, storing onboard results, transferring data to a USB flash drive, and operating as self-contained systems without connection to a computer network or Internet-based system.

The LightLab 3 LE meets the Government’s requirements for cannabinoid detection, analysis time, portability, onboard data storage, USB data transfer, battery-powered operation, touchscreen display, quality control verification, accessories, consumables, and field-deployable use. Other identified products failed to meet one or more critical requirements, including

Sole Source Determination For Actions Not Exceeding the SAT

March 2026 cannabinoid detection, THC quantification/analytical precision, relative dry weight determination, portability, battery life, or stand-alone operation. Based on the market research conducted, Orange Photonics is the only identified source offering a product that meets the Government’s minimum requirements.

5. The anticipated price will be determined fair and reasonable based on one or more of the price analysis techniques described below. (Check one and provide short explanation or description of action taken):

____ X____ Market Research.

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

_________ Current price List.

_________ Comparison with similar items in a related industry.

___ X_____ Comparison to IGCE.

_________ Contracting Officer’s personal knowledge.

____X_____ Other. Explain:

Market research identified the Orange Photonics LightLab 3 LE High Sensitivity Cannabis

Analyzer as the only identified product meeting mission requirements. Pricing was obtained through a formal quote from the manufacturer, Orange Photonics, and is consistent with the estimated total acquisition cost of identified in the Market Research Report.

The quoted price includes two (2) analyzers, required accessories, consumables for 100 scans/analyses, inside delivery, setup, initial software configuration, in-person training, and a two-year extended warranty for each analyzer.

6. Technical/Requirements Personnel Certification:

I certify that this requirement meets the Government’s minimum need and that the supporting data, which forms a basis for the Sole Source Determination (or “Justification for Brand Name Exception to Fair Opportunity”) is accurate and complete.

Technical Representative/COR Date

7. Contracting Officer Certification/Approval:

I hereby determine that the circumstances described herein exist and that the information is accurate and complete to the best of my knowledge:

Sole Source Determination For Actions Not Exceeding the SAT

March 2026

Contracting Officer Date