The U.S. Regulatory Landscape for Drone Procurement
What’s in force, what’s scheduled, what’s only proposed. A timeline for people who build and buy drone parts.
Federal drone rules started with the whole aircraft. They are moving down to the parts. Most of them bind federal buyers and their contractors, not the commercial market, and a few bind only one program. If you build drones for U.S. government customers, or sell to someone who does, the question is no longer where the drone was assembled. It is where each part came from.
Here is the timeline. What is in force, what is scheduled, what is only proposed. Every item links to the primary source.
One caveat up front. This is our current understanding of the landscape as of the post date, written by a parts manufacturer for engineers and buyers. It is not legal advice. Rules change, agencies read them differently, and your contract may ask for more than the law does. Check the primary sources and your own counsel before you act on any of it.
In force today
December 2019 · Law
Section 848, FY2020 NDAA (10 U.S.C. § 4871 note). The Pentagon can’t buy or fly drones made in China or other covered countries, or drones built with their flight controllers, radios, cameras, gimbals, ground stations, software, or network and data-storage links. Component-based: it names the parts. Read the law →
December 2023 · Law
American Security Drone Act (FY2024 NDAA). Government-wide. No federal agency may buy drones made or assembled by entities on the Federal Acquisition Security Council’s list, and from December 2025, no operating them and no buying them with federal money. Entity-based, where Section 848 is component-based. Read the act →
November 12, 2024 · Contract clause
FAR 52.240-1. Puts the act into every federal solicitation and contract from that date, and flows it down to subcontractors. On December 22, 2025 the operation and federal-funds prohibitions took effect. The prohibition is defined by who made or assembled the drone, not by what is inside it; the clause points agencies to other guidance for lower levels of assembly. Read the clause → · Federal Register →
June 6, 2025 · Executive order
EO 14307, Unleashing American Drone Dominance. Tells agencies to put U.S.-made drones first where the law allows, and sets up the Pentagon’s push to buy small drones at scale. Read the order →
December 22, 2025 · FCC
Covered List. The FCC added all foreign-produced drones and “UAS critical components” to its Covered List, plus the communications and video-surveillance equipment of the two Chinese drone makers named in the FY2025 NDAA. Covered equipment can’t get new FCC authorizations, which most radio-equipped products need to be imported or sold. Models authorized before that date can still be sold and flown. The component list names flight controllers, radios, navigation, cameras and sensors, batteries and motors. It is open-ended. It does not name airframes, which does not settle whether structures are in or out. This is an equipment-authorization rule, not a purchasing ban. In January 2026 the FCC carved out two temporary exemptions: anything on the Blue UAS list, and products that meet the Buy American domestic-end-product standard. On July 21, 2026 it extended both through January 1, 2028, and removed the expiration on its third path, Conditional Approval, for makers that commit to onshoring. Both makers have challenged the FCC actions; those proceedings are pending. See the list → · July 2026 extension →
August 2026 · Program requirement
Drone Dominance Program supply chain framework, Phase 2. An explicit sourcing timetable for structural components. Component Area 10, “Propellers, Airframe & Structural Components,” covers the carbon fiber frame, molded parts, fasteners, canopy and wiring. Phase 2 minimum: non-covered-country assembly, the applicable specialty-metal sourcing rules, and an ASDA-compliant entity. Phase 2 preferred adds non-covered-country fabrication, frame materials, connectors and wiring. Applies to vendors in that program, not to federal buying in general, and the phase dates are the program’s planned milestones; the program says they can move. Read the framework (v2, July 23, 2026) →
August 13, 2026 · Presidential proclamation
Section 232 drone tariffs. Additional import duties on top of other applicable tariffs, subject to exceptions. Not procurement rules, and they hit commercial sales too. From September 3, 2026: 100% on drones over 25 kg, thermal-imaging drones, docking stations and the critical components in Annex I; 25% on smaller drones in Annex II. From February 9, 2027: 25% on the additional components in Annex III. Rates capped at 15% for qualifying products from Taiwan, the EU, Japan, Korea, Switzerland and Liechtenstein (10% for the UK) are provided for, subject to critical-component and technology sourcing certifications and implementing guidance. They are not automatic: as of its September 2, 2026 guidance, Customs told importers not to claim those rates until further notice, and no later notice has been found as of this writing. Certain products tied to Blue UAS or FCC Conditional Approval listings got a 180-day deferral, subject to the proclamation’s conditions, and Commerce can waive duties for companies building U.S. drone plants. Whether a given part is in an annex is an HTS question for your customs broker. Read the proclamation →
Scheduled
February 9, 2027 · Tariffs
Section 232 phase two: 25% on the additional drone components in Annex III, with the same partner-country caps and conditions.
February 2027 (planned) · Drone Dominance Phase 3
What was “preferred” in Phase 2 becomes the minimum: non-covered-country assembly, fabrication, frame materials, connectors and wiring. Preferred adds Berry Amendment-compliant fasteners.
August 2027 (planned) · Drone Dominance Phase 4
Minimum: Phase 3 preferred. Preferred: assembly, fabrication, frame materials, fasteners, connectors and wiring all U.S. or nearshored. Nearshored means the Western Hemisphere, so Taiwan counts as non-covered, not nearshored.
January 1, 2028 · FCC
The Blue UAS and Buy American exemptions from the Covered List expire unless the FCC extends them again. The original January 2027 date was pushed out a year in July 2026.
December 22, 2028 · Contract clause
The FAR 52.240-1 prohibitions sunset on this date unless Congress extends them.
Proposed
Section 847 · FY2027 Senate NDAA
Would add batteries, battery cells and management systems, motors, electronic speed controllers, and more navigation and communications gear to the Section 848 list. A year after enactment, the subcomponents and raw materials of those categories. Structural materials are not in it. The House passed its own bill on July 22, 2026; the Senate has not taken up S.4784, and a compromise bill is expected in the lame-duck session. Section 847 may not survive it unchanged. Read the bill →
Commerce ICTS rule · Advance notice
In January 2025 the Commerce Department asked for comment on restricting drones and drone components from China and Russia in U.S. commerce, not just federal purchasing. No proposed rule has followed as of this writing; the regulatory agenda currently targets an interim final rule in July 2027. Read the notice →
Where drone frames come from today
Go to a composites or drone show and you will see dozens of booths selling the same part: carbon fiber plates and arms CNC-cut from laminate sheet. Ask where the sheet was laminated and the answer is often vague. Ask where the fiber in the sheet was made and it usually is.
That is the problem the rules above are circling. A cut-sheet part has three origins stacked inside it: the fiber, the sheet it was laminated into, and the shop that cut it. By one 2025 industry estimate, China holds 52.5% of the world’s carbon fiber production capacity (capacity, not output). If the laminate came from China, the shop that cuts it can be in Ohio and the laminate is still Chinese.
China holds over half the world’s carbon fiber production capacity
Carbon fiber operating capacity by country, 2025 · 326 kt global total
Until now that did not matter to most buyers. Earlier rules looked at the whole system, the supplier and a handful of electronics, and cutting is the one step a domestic shop can point to. The Drone Dominance framework is the first to make frame material and fabrication location explicit criteria. From February 2027 it asks for non-covered-country frame materials, not just non-covered-country cutting. Under that framework, a plate machined in the U.S. from a Chinese laminate would not meet the Phase 3 minimum, whatever its customs country of origin says. Buyers in that program will need the origin of the frame material, not just the shop.
Molded parts face the same question, just earlier. Whoever molds the part has to know what went into it, and has the paperwork to show it.
What it means for structures
Buyers searching for “NDAA compliant drone components” or “drone parts made in USA” are asking for more than a part number: who made it, where it was fabricated, what went into it, and whether the paperwork backs it up. Section 848 does not single out airframes, arms, prop guards or brackets as prohibited component categories today. The Drone Dominance framework is where a carbon fiber frame gets a date: requirements begin in August 2026 and tighten in February and August 2027. The Section 232 tariffs are where imported components get a price. The Drone Dominance milestones are program-specific sourcing requirements; the Section 232 measures are import duties. Neither is a blanket federal procurement ban on foreign structural parts. But the framework tells participating vendors to document frame-material origin, so expect the question.
Arris is a carbon fiber drone parts manufacturer, with molding in Berkeley, California and Taoyuan, Taiwan. Taiwan counts as non-covered, not nearshored. Location is where the question starts, not where it ends. We will work through production location, material sourcing and documentation for your program. Need U.S. production? Ask.
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This post reflects Arris’s understanding of the rules as of October 2026 and is not legal advice. Requirements vary by agency, contract and component, and proposed legislation may change or fail. Links go to the primary sources; confirm the current text before relying on it.
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