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AUVSI BRIEFING • GOAERO GLOBAL TEAM SUMMIT

The FCC Covered List & Foreign-Made Drones

What GoAERO teams building emergency response flyers need to know before testing at NASA Ames

Alexander Laska

Association for Uncrewed Vehicle Systems International (AUVSI)

September 24, 2026

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ABOUT AUVSI

The world's largest association dedicated to advancing uncrewed systems and autonomy

AUVSI unites innovators, manufacturers, operators, and policymakers across the air, ground, and maritime domains — sharing knowledge, creating market opportunities, and advocating for policies that support safe, responsible innovation in uncrewed and autonomous systems.

1972

Founded in Dayton, Ohio

60+

Countries represented in membership

AUVSI | Arlington, Virginia | auvsi.org

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THE BASICS

What is the FCC's "Covered List"?

A national-security equipment list

Created under the 2019 Secure Networks Act, the Covered List names communications equipment and services judged an unacceptable risk to U.S. national security or the safety of U.S. persons.

A functional import & sale ban

Listed equipment cannot get new FCC equipment authorization — the approval most radio-emitting devices need before they can be imported, marketed, or sold in the U.S.

HISTORICALLY: A SHORT, NAMED LIST

Huawei & ZTE

Telecom equipment & services — listed 2021

Hytera, Hikvision, Dahua

Video surveillance equipment — added 2021–22

Kaspersky & China Telecom

Software & carrier services — added 2022–24

For its first several years, the List named specific companies — almost always tied to China or Russia. That changed in December 2025.

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DECEMBER 22, 2025

The FCC's drone action was much bigger than expected

The FY25 NDAA told the FCC to list DJI and Autel equipment. The interagency national security determination went further:

Every uncrewed aircraft system & critical component made outside the U.S. — regardless of manufacturer or country.

"UAS critical components" include:

Data transmission & comms systems
Flight controllers
Ground control stations / controllers
Navigation systems
Sensors & cameras
Batteries & battery management
Motors

THE LIST HAS KEPT MOVING SINCE — NARROWING IN PLACES, WIDENING IN OTHERS

Jan 2026

Blue UAS & Buy American exemptions added

Mar 2026

First case-by-case "Conditional Approvals" granted

Jun 2026

"Toy drones" exempted outright

Jul–Sep 2026

Exemptions extended to 2028; new "military-grade" restrictions proposed

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DOES THIS APPLY TO GOAERO TEAMS?

Probably fine — but "not for sale" isn't the whole answer

What's in teams' favor

The ban blocks new FCC equipment authorization — needed to import for marketing or sale. Teams aren't selling their flyers.
FCC rules let limited quantities of RF equipment be imported for testing & evaluation, not marketed (47 CFR § 2.1204(a)(3)).
Ongoing FCC rulemakings explicitly preserve import & use for federal government use and commercial testing / product development.
Experimental licenses (Part 5) are not categorically barred for foreign-made UAS.
Off-the-shelf parts that already hold an FCC ID keep that authorization regardless of the Covered List.

Where a plan beats an assumption

Clearing the "not for sale" test doesn't by itself license you to transmit. New, uncertified radio or video links may still need an experimental license or STA.
Know which onboard RF parts already carry an FCC ID — and which are new and foreign-made.
Teams tied to a foreign government face extra disclosure rules for experimental licenses (47 CFR §§ 5.51, 5.63).
The List has changed roughly monthly since Dec 2025; a proposed "military-grade" category (heavy UAS, thermal imaging) is under review now.
Use the correct import paperwork, and ask NASA Ames early — they likely have a process from GoFly.

Bottom line: a one-off, non-commercial test aircraft is well positioned under the current rules — but that depends on getting the RF-authorization piece right, not on the sale question alone. Start early, document each component's country of origin, and check back as the fly-off approaches.

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FIRST STEPS — START NOW

What to do before you ship or travel

Inventory every RF-emitting component

Control link, telemetry, video downlink, GPS/nav. Note maker, country of manufacture, and whether it already has an FCC ID.

Ask GoAERO / NASA Ames about a centralized process

Find out whether the Fly-Off will have an event-level spectrum authorization covering all teams, before each team pursues its own.

File for an experimental license or STA if needed

For any uncertified foreign transmitter, apply through the FCC's Experimental Licensing System (ELS) under Part 5. Start months ahead —

not the week before travel.

Use the correct import declaration at the border

Declare hardware under the testing/evaluation condition on FCC Form 740, not as a sale — a paperwork step at the point of entry, separate from licensing.

Recheck the rules again closer to April 2027

The Covered List has changed roughly monthly since Dec 2025. Today's guidance may not be this fall's. Watch fcc.gov/supplychain/coveredlist.

Covered List questions: chris.smeenk@fcc.gov | Equipment authorization questions: FCC OET Inquiry Form