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Can a purchase qualify for this exception based strictly on the fact that it is a small add-on purchase to a larger contract?

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Can a purchase qualify for this exception based strictly on the fact that it is a small add-on purchase to a larger contract?

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No. While a purchase may be considered “incidental” in some situations based on its size, “incidental” in the context of section 508 means the product is being used in-house by the contractor. The size of the purchase is irrelevant for purposes of this exception. G.5.

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