The Parts Rule: The FCC Reaches Inside the Airframe

The Covered List now runs on two different logics. In December 2025 the FCC's Public Safety and Homeland Security Bureau added all UAS and UAS critical components produced in a foreign country, the list's first production location-based entry, and in the same update added the equipment listed in Section 1709(a)(1) on a producer-based determination, per the order. In January 2026 the Bureau removed certain UAS and UAS critical components from the list temporarily through January 2027, covering equipment on the Blue UAS Cleared List and equipment qualifying as a domestic end product under the Buy American standard; those deadlines were later extended to 1 January 2028, per the same document. Specific models removed under Conditional Approvals are a separate mechanism.

The 13 October rule applies only to the producer-based entries. Section 1709(a)(1) itself reaches further than two brand names: alongside equipment produced by DJI and by Autel Robotics, it lists equipment from any subsidiary, affiliate or partner of either company, any entity in a joint venture with them, and any entity with which they have a technology sharing or licensing agreement, per the statute. The FCC's Public Safety and Homeland Security Bureau and Office of Engineering and Technology have begun naming companies in proposals. A 17 July Public Notice (DA 26-742, PS Docket No. 26-184) proposes prohibiting continued importation and marketing of equipment from nine named entities. For seven of them, including Cogito Tech and Fikaxo, and for communications and video surveillance equipment from Xtra Technology, the notice relies on public reporting that the equipment consists of exact hardware copies of Section 1709 equipment, adding that it might in any case be produced by a Section 1709 partner or licensee; for Guangzhou Xaircraft Technology (XAG) it relies on foreign production rather than Section 1709, per the notice. A 10 August notice in the same docket (DA 26-832) tentatively concludes that equipment from Anzu Robotics, a US-based drone company, is covered because public sources suggest its devices are produced by an entity with a technology sharing or licensing agreement with an entity named in Section 1709, and separately because they are produced in Malaysia; the Enforcement Bureau had opened an investigation into Anzu on 8 May, per that notice.

The order made the prohibition effective 30 days after Federal Register publication, reasoning that “allowing for a lengthy transition period would allow device makers to flood the market with potentially compromised devices” and that “responsible supply chain risk assessments should have identified and mitigated risks from these entities.” It exempted pending applications because applicants who filed under the earlier rules “might not be able to substitute a replacement component without effectively restarting the authorization process,” and directed the Office of Engineering and Technology to set procedures for identifying applications eligible for the exemption.

Certification applicants already attest that their equipment is not covered and state whether they are themselves a Covered List entity, per the order. In the accompanying Further Notice of Proposed Rulemaking, the Commission says its existing certification record “centers on technical compliance and a small set of attestations” and was not designed to capture information such as the geographic origin of components, and it asks whether software and hardware bill of materials disclosures, with producer and origin reporting, would provide component-level visibility the current rules do not. Post-grant enforcement has precedent: the FCC revoked Odyssey Robot's drone and controller authorisations on 11 August after concluding they were obtained on false statements about where the equipment was produced, per DroneXL.

The same order requires any Covered List entity seeking a permissive change to equipment to apply for full recertification and bars it from the Supplier's Declaration of Conformity route for any modification. Limited waivers allowing Class I and Class II permissive changes for Covered List UAS equipment through 1 January 2029 remain in effect, per the Federal Register summary. Subject to limited exceptions, including used devices, sellers that are not high-volume third-party sellers and older listings not since amended, online marketplaces must display a certified device's FCC ID at the point of sale, with compliance dates of 1 March 2027 for marketplaces with physical access to or title over the device and 1 June 2027 for those relying on seller certification.

Three FCC notices propose limits on equipment that already holds an authorisation. The broadest is a 21 July Public Notice (DA 26-758, PS Docket No. 26-189) proposing to prohibit continued importation and marketing of foreign-produced “military-grade” UAS and UAS critical components on the Covered List, defined to include drones weighing 55 pounds or more on takeoff, drones capable of dispensing “economic poison” under FAA rules, and drones with thermal imaging or LiDAR sensors; Holland & Knight reports more than 3,800 comments, a comment period that concluded on 2 September, and that almost all commenters expressed concern. The two Docket 26-184 notices described in Signal 01 are narrower, naming specific companies, their affiliates, subsidiaries and other partners, and listed FCC IDs; comments on the Anzu notice were due by 23 September, per the Federal Register. All three notices state that the prohibitions would not apply to importation or marketing for federal government use or for commercial testing and product development, and would not affect continued use of equipment already purchased.