Key Takeaways:

• The FCC initiated two proceedings to limit the importation and marketing of devices that already have FCC equipment authorizations and are on the Covered List.
• The FCC released a public notice seeking comment on imposing such limitations on certain previously authorized: (1) foreign-produced UAS and UAS critical components; and (2) communications and video surveillance equipment produced by DJI. Comments are due August 31, 2026.
• The FCC also released a public notice seeking comment on prohibiting the importation and marketing of foreign-produced UAS and UAS critical components that already have equipment authorizations and meet the definition of “military grade.” Comments are due September 2, 2026.

The Federal Communications Commission’s (FCC or Commission) July 17 and July 21 public notices relate to the Commission’s December 22, 2025, action where the FCC added two categories of equipment to its Covered List of equipment that is deemed to pose a national security risk. Specifically, the FCC added (1) all foreign-produced UAS and UAS critical components; and (2) communications and video surveillance equipment and services listed in Section 1709(a)(1) of Fiscal Year (FY) 2025 National Defense Authorization Act (NDAA), which included equipment produced by Shenzhen Da-Jiang Innovations Sciences and Technologies Company Limited (commonly known as DJI Technologies) and Autel Robotics.

When equipment is added to the Covered List, the prohibitions generally look forward, and relate to the importation, marketing, and sale of new or modified equipment. The actions proposed in the July 17 and July 21 public notices would look backward and allow the FCC to limit the importation and marketing of previously authorized equipment. Interested stakeholders should consider submitting comments in the proceedings.

Limitation Proceeding Background. On October 28, 2025, the FCC adopted procedures that allow the Office of Engineering and Technology (OET) and Public Safety and Homeland Security Bureau (PSHSB) to place importation and marketing limitations on equipment that has existing authorizations if it is the type of equipment that would be banned by the Covered List if it were brought to market today. This limitation, if imposed, will not prevent continued use of already sold devices. The procedures for prohibiting continued importation and marketing of equipment that already has authorization require the FCC to issue a public notice and seek public comment. FCC staff will then issue determinations as to whether to prohibit the further importation and marketing of relevant devices, providing the reasons and timeline. On June 26, the FCC released its first determination prohibiting, for example, the continued importation and marketing of currently authorized:

• Telecommunications equipment produced by Huawei Technologies Company and ZTE Corporation.
• Video surveillance and telecommunications equipment, to the extent it is used for the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company and Dahua Technology Company.
• Information security products produced by AO Kaspersky Lab.

July 17 Limitation Public Notice. In this public notice, the FCC seeks comment on whether it should limit the importation and marketing of the equipment listed below. The FCC tentatively concludes that prohibiting the continued importation and marketing of such equipment is necessary to protect national security. The FCC proposes that all parties must cease all importation and marketing of the equipment within 30 days after publication of a final determination in the Federal Register. The proposed list includes:

• White-labeled devices listed in section 1709 of the FY2025 NDAA produced by the following entities:
  • Cogito, including FCC IDs 2BCHV-TQFDUB2 (specta camera drone), 2BCHV-GL3323 (unmanned aerial system (UAS) remote controller), 2BCHV-TQFDUB1 (specta mini camera drone)
  • Fikaxo, including FCC IDs 2BRQB-FKABZF and 2BRQB-YZABFI (both camera drones)
  • Lyno Dynamics, including FCC IDs 2BQ98-LD2202508 (Agricultural UAV), 2BQ98-LD220RC (remote controller), and 2BQ98-LD220RD (UAS LD220 Radar)
  • Skyhigh Tech, including FCC IDs 2BLZI-T60X2411 (Talos T60X agricultural spray UAS) and 2BLZI-YKBP22411 (UAS remote controller)
  • Spatial Hover, including FCC IDs 2BQAI-S3T (small camera UAS) and 2BQAI-NRC01 (UAS remote controller)
  • SZ Knowact, including FCC IDs 2BMUV-ARDCF25 (UAS remote controller) and 2BMUV-AUDAFV25 (small camera UAS)
  • WaveGo LLC, including FCC IDs 2BPFE-DD001 (small camera UAS) and 2BPFE-RC001 (UAS remote controller).
• Communications and video surveillance equipment listed in section 1709 produced by Xtra, to include FCC IDs 2BQH2-XCAMA01, 2BQH2-XCAMB01, 2BQH2-XCAMC01, 2BQH2-XCAMD01, and 2BQH2-XCAME01. These authorizations are for action cameras and gimbals that are believed to be white-labeled DJI products.
• Foreign-produced UAS and UAS critical components produced by XAG, to include UAS and UAS critical components with FCC IDs beginning with the 2A46G grantee code. These authorizations would cover multiple agricultural spray drones as well as remote controllers.

July 21 Limitation Public Notice. In this public notice, the FCC is seeking comment on prohibiting the continued importation and marketing of foreign-produced UAS and UAS critical components that are “military grade,” as defined below. The FCC tentatively concludes that doing so is necessary to protect national security. The FCC states that military-grade foreign-produced UAS and UAS critical components might pose even particularly acute national security risks given their capabilities. The FCC also explains that these prohibitions, if enacted, would not apply to importation or marketing of UAS and UAS critical components for use by the federal government or for the purpose of commercial testing and product development. The FCC proposes that all parties must cease importation and marketing of “military grade” UAS and UAS critical components within 180 days after publication of a final determination in the Federal Register. The FCC proposes to define “military grade” as any of the following:

1. UAS that weigh 55 pounds or more on takeoff, i.e., UAS that are not “small unmanned aircraft” pursuant to Federal Aviation Administration (FAA) rules.
2. UAS capable of dispensing “economic poison” under FAA rules.
3. UAS that contain or integrate sensors capable of thermal imaging (i.e., the capability to capture and translate the difference in temperature between objects, as well as an object’s heat signature and residual heat signature).
4. UAS that contain or integrate sensors capable of Light Detection and Ranging (LiDAR), a “remote sensing technology that measures distance by illuminating a target with a laser and analyzing the reflected light.”
5. UAS docking stations, defined as multipurpose systems that enable UAS to land safely, take off, recharge and/or replace batteries, and transfer data and payload.
6. UAS “specially designed to incorporate a defense article.”
7. Swarming UAS, defined as:

• • Ground control stations purpose-built for, or UAS integrated with flight control or vehicle management systems specially designed for, managing drone swarms, consisting of UAS that operate autonomously (without human intervention) to coordinate with each other, avoid collisions, maintain formations and dynamically respond to changes in operational or threat environments, or if weaponized, synchronize targeting activities across multiple drones.
  • UAS purpose-built to perform flights in coordinated and synchronized formations, including applications such as multi-UAS light shows, where numerous illuminated UAS work together to create synchronized aerial displays.

Conclusion. Again, the above-described proposed limitations will not impact an operator’s ability to use UAS they already own. With respect to all of the above, the FCC requests comment on how these limitations may create economic and supply chain impacts. Stakeholders will have until August 31 to provide comment on the limitations described in the July 17 public notice. Stakeholders will have until September 2 to provide comment on the “military grade” limitations described in the July 21 public notice.

Please let us know if you have questions relating to the FCC’s proposed actions or are interested in providing comments in the proceedings.