FCC Exempts Certain Drones and Components from Covered List to Address National Security Risks

The Federal Communications Commission recently issued a public notice updating its “Covered List” of restricted communications equipment to exempt certain Uncrewed Aircraft Systems and critical components. This modification came just weeks after the agency issued a public notice to add all foreign-manufactured drones and drone-critical components to the Covered List following a specific determination by an executive branch interagency body convened by the White House that they pose unacceptable risks to US national security and the safety and security of US persons.

The new exemption is expressly temporary, lasting until January 1, 2027, and is grounded in a separate and specific national security determination by the US Department of War (DoW).

Under the Secure and Trusted Communications Networks Act of 2019, the Federal Communications Commission (FCC) cannot unilaterally modify the Covered List; it must act on determinations made by appropriate national security authorities pursuant to 47 USC § 1601(c)(1). In this case, DoW made a formal National Security Determination that concluded that two classes of UAS equipment “do not currently present unacceptable risks.”

First, any Uncrewed Aircraft Systems (UAS or “drones”) or UAS-critical component that appears on the Defense Contract Management Agency’s Blue UAS Cleared List (Blue UAS List) is deemed exempted. Second, any UAS or critical component qualifying as a “domestic end product” under the Buy American Act’s standards (48 CFR § 25.101(a)) is also exempted, provided they meet US manufacturing and content thresholds.

Based on DoW’s National Security Determination, the FCC removed these categories from the Covered List, effectively exempting them from the import, sale, and authorization ban currently in place through the end of 2026, absent further action.

THE ‘BLUE UAS’ LIST

Given the central role of the Blue UAS list in the FCC’s exemption, it is worth understanding what it is and how companies and agencies can leverage it. The Blue UAS list is a DoW program to identify and field drones that meet rigorous security criteria. The program was launched by the Defense Innovation Unit (DIU) in 2020 in response to Section 848 of the National Defense Authorization Act for Fiscal Year 2020, which prohibits DoW’s use of certain foreign-made drones.

Initially, Blue UAS focused on a handful of secure drone models for military use, but it has since expanded into a broader “trusted drone” ecosystem and marketplace. In late 2025, management of the Blue UAS List transitioned from DIU to the Defense Contract Management Agency (DCMA), and DCMA’s Special Programs (US-X) now runs the Blue List portal as a hub where military and other government purchasers can find vetted UAS platforms and critical components that meet DoW’s standards for cybersecurity, data handling, and supply chain integrity.

As of the time of this writing, the Blue UAS catalog includes several approved drone models (over 39 platforms) and hundreds of cleared critical components (over 165 items) that meet US government standards for data security and resilience.

Drone manufacturers and critical component suppliers who seek a Blue UAS listing have a few options:

• Traditionally, a DoW service branch or agency can sponsor a commercial UAS to be evaluated for the Blue UAS List. This sponsorship might occur if, for example, the US Army identifies a promising agricultural drone for reconnaissance and requests DIU to fast-track its vetting. Many early Blue UAS entries were added through such military-led programs of record or DIU prototype projects.
• DIU has run initiatives (often called “Blue UAS increments”) where companies submit drones for evaluation. For example, through a Commercial Solutions Opening (CSO), DIU might invite vendors to propose drones that meet certain specs, and the winners undergo testing to be designated on the Blue UAS List.
• In 2025, DoW opened a new pathway via “Recognized Assessors.” DoW authorized third-party organizations to conduct UAS security evaluations aligned with Blue UAS standards. Notably, the Association for Uncrewed Vehicle Systems International (AUVSI) launched a “Green UAS” certification program, which DoW officially adopted as a route to Blue UAS clearance.

In practical terms, if a drone system or critical component is listed on the DCMA’s Blue UAS portal, it has been approved for DoW and federal agency procurement processes (often no waiver is required) and deemed to be free of known security “red flags,” such as unauthorized data links or banned Chinese chips. The FCC’s Covered List exemption now aligns with the Blue UAS List based on the premise that DoW has vouched for its security. The FCC also clarified that “Blue UAS” encompasses both the Blue UAS List of whole platforms and the Blue UAS Framework list of approved critical components and software, both maintained by DCMA’s portal.

BUY AMERICAN ‘DOMESTIC END PRODUCTS’

The second prong of the FCC’s exemption covers UAS and critical components that meet the Buy American Act’s definition of a domestic end product.

Under Federal Acquisition Regulation (FAR) Part 25 concerning foreign acquisition, 48 CFR § 25.101(a), a product is considered “domestic” if (1) it is manufactured in the United States, and (2) a certain percentage of its component cost is attributable to US-made (or trade-agreement) components. Recent updates to federal acquisition rules have raised these thresholds: for most products, at least 65% US component cost is required through 2028 (increasing to 75% in 2029) and for iron or steel products, no more than 5% foreign iron/steel by cost.

In essence, if a drone or critical component is primarily American-made and assembled, it can qualify as a “domestic end product,” and DoW has determined that such predominantly US-origin drones do not pose a significant supply chain risk at present. Manufacturers and purchasers should note, however, that a Buy American certification of compliance requires documentation of manufacturing location and costed bill of materials.

Specifically, FAR’s definitions focus on “cost of components” (not selling price, and not the cost of final assembly). The “cost of components” definition in FAR 52.225-1 is commonly used as a reference point, including what costs count for purchased components versus components that are manufactured in-house (including allocable overhead, excluding profit).

WHAT THE EXEMPTION MEANS FOR INDUSTRY AND USERS

Certain industry associations, such as the Commercial Drone Alliance (CDA), have generally supported the US administration’s push to reduce reliance on foreign adversary technology, but they have also flagged a practical tension in the FCC’s approach. In particular, the CDA cautioned that an overly broad scope that sweeps in UAS and critical components produced in any foreign country, rather than focusing on higher-risk jurisdictions, could inadvertently cut off inputs from close allies and, absent clear guidance and a workable transition plan, disrupt critical operations and slow innovation. The CDA’s comment highlights what many operators and manufacturers are now grappling with: compliance is not only a technical authorization question, it is also an operational resilience question.

For example, many US small UAS users, such as agricultural crop consultants and growers rely on popular models for crop scouting, spraying, and irrigation management, a significant number of which contain the same critical components that are subject to the FCC Covered List. The good news is that for day-to-day operations in 2026, agricultural drone programs can largely continue using any drones they already own since the FCC’s rules are prospective, apply to newly manufactured UAS, and do not force the grounding of previously authorized UAS. The greatest challenge will be future purchases or upgrades.

Operators must exercise caution when buying new drones or even new components (cameras, flight controllers) to ensure the exact model is FCC-approved or exempt—both short term and long term—and should consider the impact that might occur in 2027 if there is no further extension of the exemption. While the exemption provides a temporary supply line for compliant drones, it also signals that the era of mass market, foreign-made drones and critical components may be waning.

Operators should begin evaluating alternative platforms (many of which might be more expensive than the foreign-made prosumer models historically used in fields) and budget accordingly. There may also be an impact on university projects or crop consultants experimenting with new UAV technology as they must ensure that any new imports meet the exemption criteria or pursue an FCC “conditional approval” in the alternative (discussed further below).

Similar to consumers and producers of foreign-made drones, public safety agencies, including police departments, sheriff’s offices, fire departments, and other municipal drone units, are likewise affected. In recent years, many law enforcement agencies embraced small drones for tasks ranging from search-and-rescue to suspect tracking. For these agencies, if certain missions (e.g., SWAT overwatch or HAZMAT inspection) currently rely on foreign-made drones, they will need to identify Blue UAS alternatives and seek funding (grants, budget allocations) to procure those in 2026 and forward while they are exempt.

For municipal and infrastructure operators (e.g., city public works departments using drones for inspections, or county emergency management units), the considerations are similar. These entities should ensure any new drone or critical component they purchase falls under the exempted categories and should direct procurement from the vetted list of manufacturers.

It is also advisable to closely monitor for any future FCC or DHS updates, as local agencies might receive additional guidance or possibly be able to request case-by-case exemptions if a particular tool is needed. Police departments can also seek clearance for a specialized foreign-made drone not on the Blue UAS List by demonstrating its necessity and security controls. While conditional approvals are not guaranteed and would be scrutinized, they represent a possible avenue for state and local agencies to consider.

For the broader aviation and tech industry, this development underscores a larger trend: supply chain security is now a top-tier regulatory compliance issue. Just as telecommunications companies have had to assess, and in specific instances replace, certain equipment in recent years, drone and aerospace companies are now being held to a similar standard.

Businesses involved in manufacturing UAS or supplying critical components—whether making flight controllers, cameras, software, or entire aircraft—should integrate supply chain risk management into their operations. This could mean vetting second- and third-tier suppliers, tracing the origin of chips and modules, and potentially investing in domestic production capabilities for critical components.

COMPLIANCE GUIDANCE AND RISK MITIGATION STRATEGIES

For organizations across the UAS ecosystem, the following steps can help navigate the current rules and prepare for what’s ahead:

• For companies procuring drones (or critical components) in 2026, choose platforms on the Blue UAS List or those advertised as Buy American-compliant. These are presumptively allowed under the FCC Covered List exemption. Working from the Blue UAS List (which is publicly accessible via the DCMA portal) can significantly reduce compliance risk.
• For UAS manufacturers and critical component suppliers, thoroughly review the origin of all parts in their products. Identify any components that are made in or sourced from foreign adversary countries or from companies on the FCC Covered List (or NDAA Section 1709 list). These pose a potential risk of becoming “covered” equipment. Replace or re-source such components with domestic or allied-made alternatives where feasible to increase the percentage of US or allied content and the chances of passing a security risk review. During the process, manufacturers and suppliers should also thoroughly document the provenance of key components (e.g., by maintaining a bill of material)—this evidence may be needed to certify a product as a “domestic end product” meeting the 65% cost requirement.
• For a UAS product that does not squarely fit within the Blue UAS or Buy American criteria, consider proactive outreach to regulators for guidance or exemptions. Consider pursuing Blue UAS clearance for drone platforms or modules. This can be done by working with DoW directly (via a government customer sponsor) or via the new third-party assessor route. For instance, commercial drone makers can go through AUVSI’s Green UAS certification process, which as of 2025 leads to formal Blue UAS Cleared status. Interested parties can also utilize the FCC’s “Conditional Approvals” of specific devices, by submitting technical information and security justifications to drones@fcc.gov to argue that the pertinent drone/component “does not pose unacceptable risks” despite foreign origins. Engaging in this process early could yield a favorable determination or at least provide insight into what security improvements are needed. Note that any such approval will be closely tied to the exact configuration of the specific product and changes in the supply chain might necessitate reevaluation.
• For end-users of UAS (e.g., companies operating drone fleets or public agencies), coordinate with suppliers to ensure availability of replacement parts and support for approved systems. If transitioning to Blue UAS drones, consider purchasing spare batteries, controllers, and critical parts now, while they are available. Make sure those spares are the same models that are approved as even a minor revision of a part that emits radio frequency could require a new FCC authorization.
• For all interested stakeholders, because there are multiple agencies involved in this process, subscribe to updates from the FCC’s Public Safety and Homeland Security Bureau, follow DoW releases on UAS (e.g., DoW’s “Drone Dominance” spotlight), as well as any additional changes from other agencies (e.g., the Commerce Department’s easing on the export of certain UAVs classified under ECCNs 9A012 and 9A120), and engage with industry groups (like AUVSI) that track these issues. The FCC’s exemption is explicitly set to be “reassessed before the January 2027 deadline,” meaning there could be further rule changes or extensions. Public comments or industry input may be solicited in that process—so those impacted should be ready to provide feedback on how the policy is impacting their operations. Likewise, keep an eye on any state-level restrictions (as seen in states like Florida and others considering bans on Chinese-made drones) to ensure local compliance.