Understanding the Inclusion of Foreign-Made UAS and Components on the FCC Covered List

Question:

What is the primary technical concept or development discussed in DA 25-1086A1, and why is it significant?

Answer:

The core technical development discussed in DA 25-1086A1 is the addition of uncrewed aircraft systems (UAS) and their critical components, if produced abroad, to the Federal Communications Commission’s (FCC) Covered List of equipment and services deemed to pose unacceptable national security risks. This action is significant because it directly addresses growing concerns over the potential exploitation of UAS and related technologies for unauthorized surveillance, data exfiltration, and disruption of critical infrastructure in the United States. By formally restricting the use of foreign-manufactured UAS components, such as flight controllers, navigation systems, and communications devices, the FCC aims to mitigate vulnerabilities that could be exploited by adversarial actors, particularly in sensitive contexts such as public safety, mass gatherings, and critical infrastructure protection.

This regulatory move is rooted in how UAS technologies function and their inherent dual-use nature, meaning they serve both civilian and military purposes. Technically, UAS rely on a complex integration of hardware and software components to operate remotely, transmit data, and perform surveillance or delivery tasks. However, if any of these critical components—such as data transmission modules or smart batteries are produced in foreign nations, there is a risk that hidden backdoors or malicious firmware could be inserted during manufacturing. These can later enable persistent surveillance, unauthorized remote access, or even the disabling of entire fleets via software updates, as highlighted by the National Security Determination received on December 21, 2025. The inclusion of such equipment on the Covered List is a preventive measure that leverages statutory authority under the Secure Networks Act of 2019 and Section 1709 of the FY2025 National Defense Authorization Act (NDAA) to mandate that only domestically produced UAS components be used in critical applications.

For engineers, the implications are immediate and far-reaching. Any UAS or related system intended for use in public safety, government facilities, or critical infrastructure must now be scrutinized for supply chain integrity. For example, a public safety agency deploying drones for surveillance at major events like the World Cup or Olympics must ensure that all components, from the motors to the ground control stations, are manufactured in the United States or by trusted partners. This affects not only procurement but also system integration, testing, and lifecycle management. Moreover, engineers must stay informed about updates to the FCC Covered List, which was last updated on July 23, 2025, and ensure compliance with evolving national security standards.

Practically, engineers need to develop robust supply chain vetting processes and work closely with domestic manufacturers to source compliant components. This involves understanding and applying the relevant standards, such as those outlined in 47 CFR § 1.50002 (a) and 1.50003, and maintaining thorough documentation for audits. Additional requirements include designing systems with modularity in mind, so that any foreign-sourced components can be rapidly replaced if future guidance changes. Ultimately, engineers must balance innovation with security, ensuring that the deployment of UAS technology enhances operational capabilities without introducing unacceptable risks to national security.