- Taiwanese manufacturers selling or planning to sell into the United States
- Component suppliers whose parts go into US-assembled aircraft
- US integrators and importers evaluating foreign-made components
Key points
- The Covered List names essentially all drones and drone critical components produced in a foreign country. Taiwan is included.
- The test is country of production, not Chinese content and not company ownership. A clean bill of materials does not exempt you.
- It works by blocking FCC equipment authorization, which is what permits import, marketing, and sale in the US.
- Four exemptions exist, and two of them are reachable by a Taiwanese manufacturer: Blue UAS Cleared List entry, or a Conditional Approval that requires a plan to move manufacturing to the United States.
- Equipment produced exclusively for federal government use and sold to federal agencies is generally outside the restriction. The commercial channel is not.
What happened
On December 22, 2025, acting on a national security determination issued the previous day by a White House-convened executive-branch interagency body, the FCC added essentially all uncrewed aircraft systems and UAS critical components produced in a foreign country to its Covered List. The Bureau's Public Notice making the addition is DA 25-1086, which carries the determination itself in full as Appendix B.
Being covered is a restriction, not an approval. Products on the Covered List cannot receive FCC authorization, and without authorization they cannot be imported, marketed, or sold in the United States.
This was the first time the Commission applied a category-wide test based on place of production rather than naming specific companies. The approach has since been extended beyond drones to consumer routers and, in July 2026, to power inverters and advanced robotic devices.
The authority comes from the Secure and Trusted Communications Networks Act, which lets the FCC add equipment to the Covered List only after a qualifying national security authority directs it. The Commission cannot add anything on its own initiative, and it says so plainly: it is required to implement determinations made by national security agencies. The December 2025 update followed a determination by a White House-convened interagency body, which found that UAS and UAS critical components produced in foreign countries pose unacceptable risks to US national security and to the safety of US persons.
That determination also swept in the equipment and services listed in Section 1709(a)(1) of the FY2025 NDAA (Pub. L. 118-159), so the Covered List entry now reads as uncrewed aircraft systems and UAS critical components produced in a foreign country and the communications and video surveillance equipment named in that section. The agencies cited attacks and disruptions, unauthorized surveillance, and sensitive data exfiltration — and, separately from any of those, that reliance on foreign-made UAS undermines the US drone industrial base.
Two limits are worth reading precisely, because they are narrower than most summaries suggest. The restriction blocks new equipment authorizations: additions to the Covered List do not prohibit the import, sale, or use of device models the FCC previously authorized. And it does not restrict continued use — a buyer can keep operating equipment they lawfully purchased.
What counts as a "UAS critical component"
The FCC's definition names:
| Category | Sourcing page |
|---|---|
| Data transmission devices | Data Links & Radios |
| Communications systems | — |
| Flight controllers | Flight Controllers |
| Ground control stations and controllers | Ground Control Stations |
| Navigation systems | — |
| Sensors and cameras | EO/IR Cameras & Gimbals |
| Batteries and battery management systems | Battery Packs & BMS |
| Motors | Drone Motors |
The list is not exhaustive — the determination reads "includes but is not limited to". For anything not named, the FCC has published the test it applies: a UAS critical component is one designed and intended primarily for use in UAS. Its own worked example is a camera. A camera with many uses that could theoretically be attached to a drone is not a critical component; a camera designed and intended primarily as a drone camera is.
That test does most of the work on electronic speed controllers, the most commercially significant unnamed category for Taiwan. An ESC built and sold for multirotor propulsion is hard to argue out of "designed and intended primarily for use in UAS". A general-purpose motor controller that happens to suit a drone is a different case, and the distinction is about what the part was designed for rather than what it can be bolted to.
The restriction is graduated, not absolute
The restriction applies in four tiers:
1. Not a critical component. Wire harnesses, structural assemblies, fasteners, machined parts, composites, mounting hardware. Outside the definition entirely. The US commercial market for these is unaffected.
2. Critical component that never required FCC authorization. Most batteries are in this tier. These can still be sold independently, because there is no authorization for the FCC to refuse.
But they may be assessed as part of the overall analysis of any aircraft incorporating them, and a Conditional Approval applicant's onshoring plan must cover every critical component — including those needing no authorization of their own. A supplier in this tier is not barred from shipping; it becomes a line item its customer has committed to replace.
3. Critical component requiring authorization. Anything carrying a transmitter. Blocked directly.
4. Complete foreign-produced aircraft. Blocked.
The higher the value of the part, the more likely it is restricted. Structural and passive parts remain sellable into the US commercial market. Flight-critical electronics do not. Taiwan's industrial policy is pushing suppliers toward exactly the parts this rule blocks.
How literally the test is applied
SiFly Aviation is headquartered in Santa Clara, California, and still needed relief — it was in the first batch of approvals in March 2026. The trigger attaches to where a system and its components are produced, not to who owns the company. The FCC puts it plainly in its own FAQ: the specific nationality of the entity producing a UAS or critical component is not relevant to whether it was produced in a foreign country.
Taiwan is in the same position, and being an allied jurisdiction is not a category the rule recognizes.
The component rule (effective October 13, 2026)
FCC 26-50 adds nothing to the Covered List. It amends the equipment authorization rules so the existing prohibition reaches further along the half of the list that names companies. It is a second, separate test. The location test above is unchanged.
What it bars. New § 2.903(b)(2) prohibits authorization of any device that incorporates a logic-bearing hardware component produced by an entity identified on the Covered List, if the device would be prohibited had that entity produced the device itself rather than just the component.
What counts. Under § 2.902, a logic-bearing hardware component is any physical component that generates and uses timing signals above 9,000 pulses per second and uses digital techniques, or that generates and uses radio frequency energy for data processing. Purely mechanical or passive parts such as housings, fasteners, resistors, wiring and plain battery cells are out. So, at this time, are software and firmware.
Named entities only. The Federal Register summary is explicit that the prohibition "does not apply to production location-based Covered List entries (e.g., UAS, UAS critical components, or routers produced in a foreign country) unless the producing entity is independently identified on the Covered List."
Prospective. It applies to new authorization applications and does not affect previously authorized equipment. Applications pending on October 13 are exempt unless later amended to add, substitute or change a logic-bearing hardware component. Whether a component is "produced by" an entity remains a totality-of-the-circumstances test that looks to substantial responsibility for or control over design, development, manufacture or assembly.
The same order requires any Covered List entity to obtain full recertification for any change to its equipment, with no permissive-change route and no SDoC. It also requires online marketplaces to display a certified device's FCC ID at the point of sale — from March 1, 2027 where the marketplace has physical access to or title over the device, and from June 1, 2027 where it relies on a third-party seller's certification.
What this means for a Taiwanese supplier
For drones and critical components, nothing changes. They were already blocked by the December 2025 location test, and the October rule neither tightens nor loosens that.
What it adds is a check on anything that gets past the location test: tier-1 parts with electronics, Taiwanese boards inside a US-assembled aircraft that qualifies under Blue UAS or Buy American, and products holding a Blue UAS listing or a Conditional Approval. If one of those contains a logic-bearing part from a named Covered List entity — Huawei or ZTE, Hikvision, Dahua or Hytera, or an entity identified in Section 1709 of the FY2025 NDAA — authorization is refused wherever the device would have been barred had that entity made all of it.
This is narrower than "China-free". A PRC-made part from a company that is not on the Covered List does not trigger the rule, and buyers regularly conflate the two.
In a Taiwanese product, look first at thermal camera cores, RF and video SoCs, and camera modules.
What is exempt
The Commission's FAQ names four exemptions:
- Toy drones, as defined in a specific determination from the Department of War.
- Blue UAS Cleared List entries — both UAS and UAS critical components — until January 1, 2028.
- Domestic end products under the Buy American standard at 48 CFR § 25.101(a), until January 1, 2028.
- Conditional Approvals — individual determinations by the Department of War or the Department of Homeland Security that a product does not pose an unacceptable risk.
Two of the four are routes a Taiwanese manufacturer can actually take. A toy-drone determination is a product-class carve-out rather than something a supplier applies for, and a domestic end product is by definition produced in the United States. The two that remain are covered below.
Blue UAS Cleared List entry
Items on the DCMA Blue UAS Cleared List are exempt. This is covered in detail in our Blue UAS guide, including the exemption date and why the FCC's own FAQ is inconsistent about it.
Conditional Approval
Submissions go to the FCC, which forwards them to the Department of War and the Department of Homeland Security for evaluation. Guidance was issued January 7, 2026, and is summarized usefully by Akin and Holland & Knight.
Three disclosure categories are required:
Corporate structure — beneficial owners at 5 percent or more, and any foreign government ownership, control, influence, financing, or material support, including any arrangement letting a foreign government influence operations, decision-making, or access to technology.
For a Taiwanese firm holding MOEA subsidies, TASA contracts, or MND program work, this is a substantive disclosure to a foreign government, not a checkbox. Scope it with counsel before filing.
Manufacturing and supply chain — a detailed bill of materials with country-of-origin analysis, plus justification for why each foreign-made component is not produced in the United States, why those sources were selected, whether alternatives exist, and the cost of US-sourced components as a percentage of the total.
US manufacturing and onshoring plan — a time-bound plan to establish or expand US manufacturing, naming a responsible individual or office, with quarterly status reporting to the US government.
Who can apply
Both UAS producers and UAS critical component producers may apply, which the FCC's FAQ states explicitly. The Commission publishes the running list of Conditional Approvals, which is where to check whether any component-only grants have followed the first batch. In practice almost all approvals have gone to integrators of complete aircraft. Mobilicom, an Israeli datalink and controller maker, is the notable component-only exception.
What it actually commits you to
The guidance describes the process in its own terms as a transition mechanism that lets approved producers keep receiving FCC authorization while they onshore manufacturing. On that description it is not an assessment of trustworthiness that a well-documented supplier can pass.
A manufacturer with no intention of opening US production has nothing to write in the third section.
Duration
The January guidance framed approvals as lasting up to twelve months, but the first grants did not run on a rolling term — all four issued in March expired December 31, 2026, a fixed date matching the then-current Blue UAS sunset. Since July 2026, approvals continue for as long as the applicant adheres to its onshoring plan and passes ongoing vetting.
One thing this does not cost you. Entities that produce foreign-made UAS are not treated as "identified on the Covered List" — the equipment is identified by where it was produced, not by who produced it. A supplier with a mixed product line can therefore still use the streamlined SDoC authorization process for its non-covered devices. The exception is entities named in Section 1709(a)(1) of the FY2025 NDAA, who lose it. The Third FNPRM proposes to require certification for every device in a Covered List sector, UAS and UAS critical components included, regardless of producer — see Open questions.
The federal-use question
Drones produced exclusively for federal government use and sold to federal agencies generally do not require FCC equipment authorization at all, which places them outside the restriction. The determination carved out military use; the Covered List that implements it contains no exemption for commercial use.
The operative word is exclusively. A component sold to a US manufacturer serving both federal and commercial customers is not obviously inside that carve-out.
Practical consequence. In the United States, it is the civilian and commercial channel where the restriction has the biggest impact, while the government channel remains open to suppliers who can satisfy Section 848 and the procurement rules that apply there.
If you are buying from Taiwan
The Covered List is your problem before it is your supplier's, because the authorization you need is for your finished aircraft.
If you assemble in the US. The FCC answers this one directly: a UAS produced in the United States containing foreign-produced components is not covered if it complies with the Blue UAS Cleared List or the Buy American standard. Satisfy neither and the aircraft is still not foreign-produced, so it is not on the list on that basis, but the foreign critical components inside it are — and the route through that is a Conditional Approval whose onshoring plan must name every one of them — including components that never required FCC authorization of their own. A Taiwanese flight controller does not block your application. It becomes a line item you have committed to replace on a stated schedule.
If you assemble outside the US. The aircraft itself is on the list regardless of what is inside it. Component sourcing does not change the outcome.
What to ask a Taiwanese supplier. Where the board is manufactured, not where it is designed. That distinction decides the outcome. Whether the specific SKU carries a transmitter, which determines whether it needs authorization in its own right. Whether they hold or are pursuing Blue UAS listing, which is the most direct exemption available to them. And whether any logic-bearing component on the board comes from a named Covered List entity, and whether they can produce a bill of materials showing the source.
What not to assume. A supplier's China-free documentation does nothing for the location test, however rigorous it is. It matters under Section 848 and the Section 232 allied cap, which test Chinese content. From October 13, 2026, a narrower check applies to whatever clears the location test: whether it contains a logic-bearing component from an entity named on the Covered List. That check is about named companies, not Chinese content in general.
What this does not cover
Market access is one problem. Landed cost is another, and it is governed separately by the Section 232 tariffs, most of which have been in effect since September 3, 2026.
Open questions
These were unresolved as of the review date above. Everything below drawn from the Third FNPRM is proposed, not in force.
- Import and marketing prohibition. The October 2026 rule did not adopt one. The Third FNPRM proposes a § 2.1204(c) under which covered equipment could be imported only with a valid authorization, in quantities of 40 or fewer for testing, evaluation or product development, solely for export, or for US Government use, and a § 2.803(d)(3) prohibiting the marketing of covered equipment that lacks an authorization. If adopted, the tier-2 position above — bare boards can still ship — changes.
- ESCs. Whether ESCs count as critical components. The Third FNPRM proposes to codify the UAS critical components list: data transmission devices, communications systems, flight controllers, ground control stations, navigation systems, sensors and cameras, batteries and battery management systems, and motors, designed and intended primarily for UAS use. ESCs are still not named.
- Component-only Conditional Approvals. Whether DoW will grant component-only Conditional Approvals to applicants without US production plans.
- HBOM/SBOM disclosure. The Third FNPRM proposes that certification applicants file a signed hardware and software bill of materials identifying, for each critical component, its producer, its production location or locations, and the percentage of component value attributable to each, updated within 30 days of a material change. Each producer's legal name, trade names, jurisdiction of incorporation and contact details would be required. The FCC's preliminary cost estimates are up to $10,000 per hardware device and under $5,000 per software program.
- Certification for all Covered List sector devices. The Third FNPRM proposes that any device in a Covered List sector — UAS, UAS critical components, routers — go through certification regardless of producer, even if it would otherwise be eligible for SDoC or exempt from authorization. If adopted, the SDoC route described in the note under Conditional Approval would no longer be available for devices in those sectors.
- Codified "produced in a foreign country". The Third FNPRM proposes a definition tied to the domestic end product standard at 48 CFR 25.101(a). Its proposed rule text reads that a device is produced in a foreign country if it "either: (1) Does not qualify as a domestic end product as that term is defined in 48 CFR 25.101(a); and (2) Is designed or developed in a foreign country." It also asks whether the term should be read more broadly, aligned with the FTC's "Made in USA" standard, or more narrowly, aligned with trade-law rules of origin.
Primary sources
- DA 25-1086 — the December 22, 2025 order adding foreign-produced UAS to the Covered List
- FCC Covered List
- Covered List FAQs: UAS and UAS critical components
- Conditional Approval submission guidance, January 7, 2026
- DA 26-253 — first UAS conditional approvals
- DA 26-761 — July 2026 extension
- 91 FR 57798 — FCC 26-50 Final Rule (Third Report and Order), published September 11, 2026, effective October 13, 2026
- 91 FR 51139 — FCC 26-50 Third Further Notice of Proposed Rulemaking, published August 7, 2026
- FCC 26-50 — full text of the Third Report and Order and Third FNPRM, adopted July 22, 2026
Questions the rule raises
Does the Covered List stop us shipping parts we already sell into the US? No. The restriction blocks new equipment authorizations. Device models the FCC has already authorized can still be imported and sold, and buyers can keep using equipment they lawfully bought.
Our board has no Chinese content at all. Does that help? Not under this rule. The test is where the product was produced, not what is inside it. The documentation is valuable under Section 848 and the Section 232 allied cap, which do test content.
We are a Taiwanese company, not a Chinese one. Does that matter? No. The FCC states that the nationality of the producing entity is not relevant to whether a component was produced in a foreign country. A Swiss company and a California-headquartered company both needed relief.
Is our camera a UAS critical component? It depends on what it was designed for. A camera with many uses that could be attached to a drone is not a critical component. A camera designed and intended primarily as a drone camera is.
Our batteries never needed FCC authorization. Are we affected? Nothing that did not previously require authorization now requires it, so a generic battery is not newly caught. But a Conditional Approval applicant's onshoring plan has to cover every critical component, including ones needing no authorization of their own.
Are drone docks covered? Yes. They fall inside the definition of UAS and UAS critical components.
Can a component maker apply for a Conditional Approval, or only aircraft manufacturers? Both. The FCC states that UAS producers and UAS critical component producers can apply.
Can we still use the streamlined SDoC process for our other products? Yes, unless you are an entity named in Section 1709(a)(1) of the FY2025 NDAA. Producers of foreign-made UAS are not treated as identified on the Covered List, because the equipment is identified by where it was produced rather than by who produced it.
Does the October 2026 component rule change our position? Not for drones and critical components, which the December 2025 location test already blocks. For anything that clears that test, it adds a second check: from October 13, 2026, a new authorization is refused if the device contains a logic-bearing component from a named Covered List entity and the device would have been barred had that entity made all of it.
Is "no Covered List parts" the same as "China-free"? No. The component rule reaches only parts from entities named on the Covered List, so a PRC-made part from a company that is not on the list does not trigger it. China-free documentation answers a broader question about Chinese content that this rule does not ask.