FCC Covered List and C-UAS: What It Means

What Happened: FCC Covered List Addition

On December 22, 2025, the Federal Communications Commission (FCC) published a final rule designating foreign-made unmanned aircraft systems (UAS) as a "covered item" under Section 889 of the National Defense Authorization Act (NDAA). This marked the first entire product category added to the Covered List since the FCC's telecommunications equipment restrictions (which initially targeted Huawei and ZTE equipment).

The Rule:

• Effective date: December 22, 2025
• Coverage scope: All foreign-made unmanned aircraft systems + integral components (batteries, communications modules, sensors, propellers) manufactured or developed outside the United States
• Primary impact: Import, sale, and marketing of affected systems in U.S. commercial and federal channels are prohibited
• Exemption: Domestic manufacture is permitted; components manufactured domestically and assembled in foreign jurisdictions may fall outside the rule (legal interpretation still developing)

Key Language from the Rule:

The FCC defined "foreign-made unmanned aircraft systems" to include all platforms, regardless of size classification, that are:

1. Manufactured or developed outside the United States
2. Designed to carry surveillance or imaging payloads
3. Capable of autonomous or remote flight

This language intentionally captures DJI platforms (the vast majority of commercial and consumer drones), European platforms (Freefly, senseFly), and Chinese competitors (Auterion, EHang, XAG).

What the Rule Actually Does—and Doesn't Do

What the Rule Accomplishes

Import/Marketing Prohibition:

The rule prevents FCC-licensed importers and retailers from bringing foreign-made UAS into U.S. distribution channels. This eliminates:

• DJI platforms from authorized dealer networks (Best Buy, B&H Photo, Amazon authorized sellers)
• European professional drones from formal U.S. distribution channels
• Government supply contracts for foreign-made platforms

Component-Level Restriction:

The rule extends to integral components—meaning:

• Batteries manufactured outside the U.S.
• Communication modules (RF transceivers) sourced from foreign suppliers
• Camera gimbals and sensors
• Flight control computers

This breadth forces any entity assembling drones in the U.S. to source critical components domestically or face Covered List compliance friction.

Domestic Manufacturing Exception:

A narrow exception permits U.S.-based manufacturing of drones using foreign-sourced components, provided:

• Final assembly occurs in the U.S.
• The firm demonstrates intent to domestically source critical components within specified timelines
• Compliance documentation is provided to the FCC

This carve-out is intended to encourage DJI, Auterion, and others to establish U.S. manufacturing—effectively reshoring production while maintaining platform continuity.

What the Rule Does NOT Do

Does not eliminate existing platforms:

The rule is prospective. DJI Mavic 3, Phantom 4, Avata, and thousands of other foreign-made drones already in U.S. airspace, private hands, and government inventories remain legal to operate. The rule does not require destruction or seizure of existing inventory.

Does not regulate operation:

The rule applies to importation and marketing—not to flight operations. A DJI Mavic 3 operator can legally fly their drone today and tomorrow; the rule does not affect individual operators.

Does not address autonomous or DIY platforms:

The rule targets "unmanned aircraft systems" in organized commerce. It does not prohibit:

• Home-built drones assembled from discrete components
• Open-source autopilot systems (ArduPilot, PX4)
• Autonomous platforms without explicit supply-chain traceability
• FPV racing drones marketed primarily for entertainment (regulatory gray area)

A sophisticated adversary can bypass the rule entirely by sourcing components and assembling platforms autonomously.

Does not regulate gray-market distribution:

The rule applies to FCC-regulated importers and authorized retailers. It does not prevent:

• Direct international shipping from foreign retailers to U.S. consumers (gray market)
• Purchases by government entities with explicit foreign-procurement authority (military agencies, intelligence community)
• Platforms sourced through non-FCC-regulated channels

What It Means for the Drone Threat Landscape

Existing Platforms Remain Operational

The immediate effect of the rule is limited. DJI platforms (Mavic, Phantom, Avata, Mini series) represent approximately 70% of the commercial and consumer drone installed base in the U.S. The rule does not require decommissioning existing inventory.

Threat implication: Organizations relying on DJI platforms for critical operations (infrastructure inspection, emergency response, agriculture) face operational continuity, not prohibition. However, they can no longer procure new platforms through authorized channels.

Gray-Market Supply and Pricing Dynamics

The rule will accelerate gray-market distribution:

• DJI, Auterion, and other foreign manufacturers will continue selling platforms through indirect channels (eBay, Amazon Marketplace, international resellers)
• Pricing for foreign-made platforms will increase (gray-market premiums, logistics friction, supply uncertainty)
• Institutional buyers will face increased compliance overhead (demonstrating imported platform necessity for waivers or exemptions)

Threat implication: Threat actors with resources to navigate gray-market sourcing face higher costs but not fundamental denial. Accessible platforms remain accessible; entry barriers increase marginally.

Domestic Manufacturing as Loophole

The rule's domestic-manufacturing exception is a significant loophole. Within 18 months, expect:

• DJI U.S. manufacturing announcement (company has publicly committed to establishing U.S. production)
• Auterion Skynode domestic assembly (European platform, likely to establish U.S. presence to avoid Covered List friction)
• Strategic partnerships between foreign platform makers and U.S. manufacturers

Threat implication: Platforms currently banned from import will re-enter U.S. distribution through "American-made" variants—functionally identical but manufactured domestically. The rule's long-term effect on threat landscape is minimal unless enforcement includes post-manufacture components.

Autonomous and DIY Platforms Bypass the Rule

A critical gap: the rule targets organized supply chains, not autonomous capability development.

• DIY autonomous platforms: Hobbyists and adversaries can assemble platforms from off-the-shelf electronics (flight controllers, RF modules, sensors) without falling under "unmanned aircraft systems" marketed commercial designation
• Open-source autonomy: ArduPilot, PX4, and similar autopilots are freely available; integration into DIY platforms is unregulated
• 3D-printed airframes: Manufacturing airframes domestically avoids Covered List friction entirely

Threat implication: Sophisticated threat actors are unaffected. The rule impacts commercial drone supply; adversarial platforms that already operate outside commercial markets are unimpeded.

What It Means for the C-UAS Industry

The rule creates cascading effects for counter-drone technology vendors and operators.

Testing and Calibration Complexity

C-UAS vendors rely on access to diverse platform samples for:

• RF signature library updates (D-Fend Labs, Sentrycs, Dedrone require current DJI, Auterion, XAG samples to maintain detection algorithms)
• Kinetic testing (Fortem Coyote, Rheinmetall Skyranger require drone targets for lethality validation)
• Sensor calibration (EO/IR vendors require platform samples for thermal signature characterization)

The rule restricts vendor access to new platforms:

• Domestic availability: Only older or refurbished platforms available through gray market
• Regulatory exemption friction: Vendors must obtain FCC waivers to legally import platforms for testing
• Supply uncertainty: Calibration schedules become unpredictable when platform availability is constrained

Practical impact: C-UAS vendors face increased development timelines and cost per platform update cycle. Detection library updates—previously achievable on 6–12 month cycles—may extend to 18–24 months.

Protocol-Level Vendor Vulnerability

RF-domain vendors (Sentrycs, D-Fend, Dedrone) are especially exposed because their algorithms depend on maintaining current protocol libraries:

• DJI protocol changes (the company updates C2 encryption, hopping parameters, and modulation regularly)
• Foreign platform proliferation (as DJI faces import restrictions, competitors introduce new platforms with unknown RF signatures)
• Detection lag risk: Algorithms relying on known protocol fingerprints become outdated; new platforms are initially undetected

Vendor response: Expect protocol-level vendors to: 1. Invest in physics-based RF detection (autonomous platform signatures) as backup to library-dependent methods 2. Accelerate U.S.-based testing partnerships with domestic manufacturers 3. Lobby for vendor exemption pathways in FCC rulemaking

RF Signature Changes and Implications

A secondary effect: manufacturers accelerating platform updates to circumvent detection libraries.

• DJI next-generation platforms may implement new RF protocols specifically to address regulatory pressure
• European alternatives (Freefly, senseFly, Quantum Systems) will market "Covered List compliant" domestic variants
• RF landscape fragmentation: No longer a small number of dominant platforms; vendors face detection burden across 10+ manufacturer ecosystems

Implications for Organizations

Institutional Buyers with Foreign Platforms

Organizations currently relying on DJI, Auterion, or other foreign platforms face an operational decision:

Immediate options:

1. Maintain existing inventory (platforms already in service remain legal to operate)
2. Gray-market procurement (source replacements internationally, higher cost, reduced support)
3. Switch to domestic alternatives (Verizon SkyCye, American Robotics, Archer Aviation platforms—all significantly more expensive)
4. Obtain FCC exemption (demonstrate operational necessity; exemption process takes 3–6 months)

Cost implications: Organizations currently procuring DJI platforms at $500–5,000 per unit will face alternatives at $15,000–50,000+ per unit, representing 10–50x cost increase.

Government Entities

Federal agencies face explicit restrictions:

• FAA procurement authority: Exemption to import foreign platforms for official use
• DoD restrictions: Most aggressive (Section 889 originated from defense supply chain concerns)
• Civilian agency flexibility: FEMA, USGS, Interior Department have more latitude but face bureaucratic friction

Practical impact: Government agencies will establish domestic platform approval lists (American Robotics, Verizon SkyCye, etc.) creating procurement complexity and cost escalation.

C-UAS Operators

Organizations implementing counter-drone systems must account for threat landscape shifts:

Detection algorithm impact:

• RF-domain systems: Expect reduced detection confidence as platform diversity increases and protocol libraries lag
• Multi-sensor systems: EO/IR and radar become more critical for maintaining coverage during RF-library transition periods
• Kinetic systems: Platform diversity increases calibration burden; operators must validate engagement effectiveness against new platforms

Recommendation: Organizations deploying C-UAS should:

1. Prioritize multi-sensor (RF + EO/IR + radar) systems over RF-only detection
2. Establish platform-agnostic detection approaches (physics-based RF analysis rather than signature matching)
3. Validate C-UAS effectiveness against diverse platform types (not just DJI)
4. Plan for detection library refresh cycles (expect 12–18 month update cadence as platforms evolve)

What Organizations Should Do

Strategy 1: Platform-Agnostic Detection

Preference: Multi-sensor and physics-based detection systems that do not rely on protocol libraries.

• Physics-based RF: D-Fend Labs' approach (identifying autonomous flight behavior via RF micro-Doppler rather than protocol signature)
• Multi-sensor fusion: Fortem, Dedrone, Hensoldt systems that integrate RF, EO/IR, radar for redundancy
• Avoid: Protocol-library-dependent systems (Sentrycs, pure RF-signature vendors) in isolation

Rationale: As platforms diversify and protocols evolve, signatures become obsolete; physics-based detection maintains effectiveness across platform diversity.

Strategy 2: Regulatory Awareness

Recognize that the Covered List rule does not eliminate threat; it reshapes threat topology:

• Existing platforms remain operational: Threat actors already have access; rule does not degrade capability
• DIY and autonomous platforms unaffected: Sophisticated adversaries use non-commercial platforms; rule has minimal impact
• Gray-market supply persistent: Rule enforcement creates friction but not denial

Implication: C-UAS procurement should not assume rule reduces threat. Instead, plan for threat persistence and focus on detection/mitigation that adapts to platform diversity.

Strategy 3: Vendor Resilience Assessment

When evaluating C-UAS vendors, assess vulnerability to Covered List impact:

Red flags:- Vendor relies entirely on RF-domain, signature-based detection - Vendor has limited domestic testing partnerships - Vendor has not announced platform-agnostic or autonomous-resistant detection - Vendor has no clear path to independent testing/calibration

Green flags:- Multi-sensor architecture (RF, EO/IR, radar redundancy) - Physics-based detection algorithms - Published autonomous-platform testing (demonstrates detection effectiveness against non-commercial platforms) - Established domestic testing partnerships and exemption pathways

Longer-Term Outlook

Domestic Manufacturing Acceleration

Expect within 18 months:

• DJI U.S. manufacturing facility operational (likely in Texas or Arizona)
• Auterion/Quantum Systems domestic partnerships established
• U.S.-only variant platforms introduced (functionally equivalent, domestically manufactured)

Effect: Rule's long-term supply disruption is minimal; platforms re-enter market through domestic manufacturing loophole.

Protocol and Design Divergence

As manufacturers diversify (DJI U.S. variant, Auterion domestic assembly, European alternatives), platform protocols will diverge:

• Fragmentation: Detection vendors must maintain 15+ protocol variants instead of 3–5
• Update frequency: Library maintenance burden increases significantly
• Detection lag: Time between new-platform introduction and detection-library update increases

C-UAS implication: This creates sustained advantage for multi-sensor, physics-based vendors over pure RF signature approaches.

Regulatory Escalation Risk

The rule is prospective; regulatory escalation is likely:

• Component-level restrictions: Future rules may ban specific RF modules, batteries, or sensors (extending Covered List beyond platforms to subcomponents)
• Software restrictions: FAA/FCC may restrict flight control software (ArduPilot, PX4) if deemed "foreign-developed" (unlikely but discussed in policy circles)
• Operational restrictions: Rule may evolve from supply-chain to operational restrictions (flight authorization based on platform certification)

Key Takeaway

The FCC Covered List addition is a supply-chain restriction, not a threat reduction. Existing platforms remain operational; threat actors access platforms through gray markets; DIY and autonomous platforms bypass the rule entirely.

For C-UAS procurement, the rule's significance lies not in immediate threat reduction but in forcing vendors and operators to adapt detection approaches. Organizations should prioritize platform-agnostic, multi-sensor systems that maintain effectiveness as the threat landscape diversifies.

The rule signals regulatory intent to constrain foreign-made platforms but does not achieve the intended objective of reducing threat surface. Sophisticated adversaries and established threat actor supply chains are largely unaffected. The rule's primary impact is on commercial ecosystem fragmentation and C-UAS vendor complexity.

Related Reading

• DroneShield
• Dedrone
• SAFER SKIES Act
• Commercial C-UAS Market