Engineering Benefits of Adding Foreign-Produced UAS and Critical Components to the FCC Covered List

Question: 

What are the advantages or benefits for engineering applications of the FCC’s decision to add foreign-produced Uncrewed Aircraft Systems (UAS) and their critical components to the Covered List as outlined in DA 25-1086A1?

Answer: 

The primary benefit of the FCC’s decision to add foreign-produced UAS and their critical components to the Covered List is the enhancement of security and reliability in engineering applications that depend on these technologies. By restricting the use of equipment identified as posing an “unacceptable risk to national security” (as determined by a December 21, 2025, National Security Determination), engineers can be more confident that their designs and systems are less vulnerable to unauthorized surveillance, data exfiltration, or remote disabling. This is particularly important in sectors such as critical infrastructure, public safety, and defense, where system integrity is paramount, and any compromise could have far-reaching consequences.

From a technical perspective, foreign-manufactured UAS and components, including data transmission devices, communications systems, and flight controllers, have been shown to pose risks, such as persistent surveillance and remote access via software updates, as highlighted in the cybersecurity guidance referenced in the FCC notice. By mandating that these components be produced domestically, the FCC creates a controlled supply chain, reducing potential entry points for malicious code or hardware backdoors. This is a direct application of the broader engineering principle of “security by design,” which emphasizes building robust systems that anticipate and mitigate threats at every level, from hardware to software.

For engineers, this regulatory move simplifies risk assessment and procurement decisions. Instead of individually vetting foreign-sourced components for hidden vulnerabilities or compliance with U.S. standards, engineers can rely on the Covered List as a clear guideline. This not only streamlines the design and integration process for applications like public safety drones, infrastructure monitoring, and government facility surveillance, but also reduces the administrative burden of ongoing security audits. For instance, choosing UAS components not flagged by the FCC (per the updated list as of July 23, 2025) helps ensure compliance with both federal and industry cybersecurity standards, such as those outlined in the Secure Networks Act and the FY2025 NDAA.

However, these benefits come with important requirements and considerations for engineers. Projects must now ensure full traceability of UAS components to domestic sources, which may affect supply chain logistics and increase costs in the short term. Engineers must update procurement policies, documentation, and system design specifications to align with the FCC’s rules (47 CFR § 1.50002, 1.50003), and remain vigilant for ongoing updates to the Covered List. In practice, this means closer collaboration with U.S.-based suppliers, rigorous component validation, and proactive monitoring for regulatory changes—a shift that ultimately fosters a more secure and resilient engineering environment.