Amid the disruption everywhere in federal contracting, we’re often asked: what will stick, and what’s just the churn of the moment? Our answer is to look past any single announcement to the direction of travel. Smart investments in areas where the policies persist across administrations are the ones that pay the biggest dividends. One persistent policy across the past three administrations, and multiple Congresses, is the drive to secure friendly supply chains for critical industries, none more so than drones, robotics, and advanced electronics.

The latest example of this effort to reduce supply chain vulnerability is the July 28, 2026, FCC action to add foreign-produced advanced robotic devices (expressly including humanoid robots, quadrupeds, and autonomous mobile robots) and power inverters to its “Covered List.” This is the third broad restriction on foreign-produced products imposed by the FCC in seven months, following drones in December and consumer-grade routers in March, and each has been built on the same authority: a national security determination resting on supply chain vulnerability and cybersecurity risk, a prospective closure of the equipment-authorization pipeline, and the Pentagon holding Conditional Approval authority. The FCC “Covered List” is now a central part of the standing playbook for attempting to limit the impact of supply chains reliant on China and countries of concern.

The U.S. efforts are seeking to answer Beijing’s successful efforts over the last twenty years to systematically corner key markets relevant for the robotics and drone industries, as well as other key industries of the future. By most estimates, between 85 and 90 percent of the humanoid robots shipped worldwide in 2025 were by Chinese companies, and a single Chinese manufacturer has for years accounted for the overwhelming majority of the small drones flown in the United States and globally. The formula—manufacture at scale, subsidize, vertically integrate, collapse costs—is the same one that delivered Chinese dominance in solar panels, batteries, and electric vehicles, and it runs down to the component base beneath the machines: rare-earth magnets, actuators, precision motors.

U.S. policymakers have understood this for years, and through everything else that has changed under this administration (a FAR rewritten end to end, “speed to capability” and “85% solutions” displacing process as the Pentagon’s guiding principles, CMMC phased in, paused, and reshaped) supply chain security regulation has moved in only one direction. This installment of Autonomy Decoded maps the latest in supply chain regulations relevant for industry and provides some practical strategies for operating under rules that should be treated as a permanent part of an enduring trend. As industrial policy and national security interests converge, on-shoring of supply chains for robotics and drones is here to stay and with Gauntlet II, the next phase of the Drone Dominance Program, expected in late August 2026 and other opportunities rapidly unfolding, understanding this environment will help secure enduring success in the U.S. federal market.

NDAA Compliance Goes Government-Wide

Congress built the first layer of the recent push for supply chain security and resilience around the Pentagon: Section 848 of the National Defense Authorization Act (NDAA) for fiscal year (FY) 2020 barred the Department from procuring or operating unmanned aircraft systems (“UAS”) manufactured or managed by covered foreign entities.  This limit applies not just to airframes but also flight controllers, radios, cameras, gimbals, ground control systems, and operating software. Section 817 of the NDAA for FY 2023 and the Section 1260H entity list added further restrictions focused on China, a regime we detailed in our installment on shifting regulation. The American Security Drone Act of 2023 (“ASDA”) then took that architecture across the entire federal government. Its implementing clause, FAR 52.240-1, entered new solicitations and awards on November 12, 2024 and, critically, flows into legacy contracts at the next option exercise or period-of-performance modification. Note where the clause resides: FAR Subpart 40.2, “Security Prohibitions and Exclusions.” Even as the Revolutionary FAR Overhaul strips requirements from the FAR wholesale, its June 2026 proposed rule preserves the government’s supply chain security provisions in Part 40. Deregulation is sweeping the FAR but is certainly not sweeping away these security-focused rules.

The regime reached full strength on December 22, 2025, when the operate and fund prohibitions joined the delivery bar already in effect. Contractors may not:

  • Deliver: provide a Federal Acquisition Security Council (FASC)-prohibited UAS as a contract deliverable;
  • Operate: use a FASC-prohibited UAS in the performance of a contract, even where the drone itself is not what the government is buying; or
  • Fund: use Federal funds for the procurement or operation of a FASC-prohibited UAS.

For NDAA compliance purposes, the screening rule is simpler than it sounds: the FASC list published in SAM.gov incorporates every entity on the Consolidated Screening List: DJI, Autel Robotics, Aerospace CH UAV, and JOUAV among them. Agency heads hold case-by-case waiver authority under FAR 40.202-6.

FCC Flexing Its Authorities

On December 22, 2025, the same day the ASDA went into full effect, the FCC added all foreign-produced UAS and UAS critical components to the Covered List, implementing a National Security Determination issued the day before. Under the Secure Networks Act and the Secure Equipment Act, equipment added to the FCC’s Covered List at the direction of national security authorities cannot receive the equipment authorization required to import or market a radio-frequency device in the United States.  Therefore, the FCC’s reach extends to the entire commercial market, not just federal procurement.  This action was prompted by Section 1709 of the NDAA for FY 2025, which effectively required the addition of DJI and Autel Robotics to the Covered List, but the administration went significantly further.  As the past seven months have confirmed, country of production is now the organizing principle of U.S. autonomy supply chain regulation.

The FCC action is prospective only, not affecting existing U.S. based owners of affected products. The authority rests on equipment authorization: the pipeline through which any radio-frequency device must pass before import or sale. What that means in practice for every manufacturer still seeking authorizations is that applicants must certify in good faith that a device was not “produced in a foreign country”, which turns on where the device is produced, not who produces it. A false certification invites FCC enforcement and, where the same representations flow into federal contracts, False Claims Act exposure.

Onshoring Accelerates: Blue List, Green List, and Conditional Approvals

The FCC’s market-wide restriction required relief valves, given that the UAS industry is so dependent on China and few alternatives are sufficiently mature. On January 7, 2026, the FCC exempted two UAS categories from the Covered List: UAS and critical components on the Blue UAS Cleared List, and “domestic end products” under the Buy American standard; drones built exclusively for federal government use fall outside the prohibition entirely. Functionally, this exemption means that the Blue UAS (launched by the Defense Innovation Unit in 2020 as the Pentagon’s answer to Section 848 with AUVSI’s Green UAS certification now a recognized pathway onto the Cleared List as we mapped in our swarms installment) became the safe harbor for the entire commercial market. A defense compliance program built under one administration is now, under another, the front door to selling “NDAA-compliant” drones in America.

Despite the restrictions, there is a pathway to approval: companies can ask for a Pentagon security review followed, where no unacceptable risk is found, by an FCC “Conditional Approval.” The first approvals were announced on March 18, 2026, and on July 21, 2026, following a further Pentagon determination, the FCC announced that Conditional Approvals no longer expire automatically at the end of 2026 but run indefinitely, for as long as the manufacturer continues to follow its approved onshoring plan and passes ongoing government vetting, and extended the Blue UAS and Buy American exemptions through January 1, 2028.  This move effectively flexes a national security authority for, at least in part, industrial policy purposes.  An onshoring plan submitted to obtain a Conditional Approval is no longer a business projection but a durable requirement if the Conditional Approval needs to be relied on.

Robotics Centerstage

There should now be no doubt that the FCC’s late 2025 drone action was not a one-off. On March 23, the FCC added all consumer-grade routers produced in a foreign country to the Covered List, with Conditional Approvals available from the Pentagon or DHS and a blanket waiver preserving security updates for previously authorized models. Then came the July 28 addition of foreign-produced advanced robotic devices and power inverters on the same architecture, with the Conditional Approval gate held by the Pentagon (and, for inverters, DHS).

The robotics definition covers the machines at the center of the autonomy economy. An “advanced robotic device” is, in essence, any mobile machine more than 4.4 pounds (docking station included) capable of ground locomotion, navigation, or obstacle avoidance that combines three things: a sensor that perceives its environment, network connectivity of at least 200 kbps, and software (local or remote) controlling its autonomous navigation, movement, perception, data collection, or command-and-control. Autonomous mobile robots, humanoid robots, and quadrupeds are named expressly. That is, functionally, a definition of the modern robot. The exclusions are instructive: uncrewed aircraft are carved out because they are already covered otherwise; connected vehicles because Commerce’s ICTS rule occupies that lane; surgical and medical robotics, prostheses, mobility aids, and fixed industrial robots are spared — for now.

Two features of the July 28 action are important to highlight:

  • First, the FCC defined “foreign-produced” for these categories by reference to the Buy American Act — a device escapes coverage only if it is manufactured in the United States and the cost of its domestic components exceeds 65 percent of total component cost. The exemption standard from the drone entry has become the coverage standard in the latest action. Across the FAR, the FCC, and the incentive programs described below, a single country-of-production test, the Buy American domestic end product, is quietly consolidating into the master key of the U.S. autonomy market.
  • Second, the Conditional Approval process now demands what amounts to a foreign ownership, control, or influence (FOCI)-style national-security review of the applicant: ownership structures to the 5 percent beneficial-owner threshold, a component-level bill of materials by country of origin, including the entities controlling IP and software updates and any sole-source single points of failure, and a capital-committed, time-bound U.S. onshoring plan with quarterly progress reporting. Practitioners who have shepherded clients through FOCI reviews or CFIUS filings will recognize the questions. The government is now probing robotics manufacturers the way it reviews cleared contractors and foreign investments — scrutiny that, under Section 847, will soon extend to unclassified defense contracts. The July 28 action is prospective only. Previously authorized models may continue to be sold and used, federal government purchases are not restricted, and small prototype batches may be imported for development and testing. Companies on either side of affected transactions should be reviewing their contracts now: change-in-law and force majeure doctrines will be tested as supply commitments made before July 28 collide with an authorization pipeline that no longer exists.

Building a Domestic Base

Restriction is only half of the campaign. Section 833 of the NDAA for FY 2026 requires continued implementation of the Pentagon’s Supply Chain Illumination program, which requires major systems contractors to submit supply chain information, and authorizes interim “national security waivers” through January 1, 2028 for contractors that promptly disclose noncompliant sources identified through their illumination systems. Congress and the FCC are now rewarding exactly the same behavior. A mapped, documented, promptly disclosed supply chain buys a statutory waiver on the procurement side and a durable exemption on the market access side.

All of this makes joint ventures and partnerships with foreign companies willing to manufacture in the United States in order to sell to the U.S. Government that much more enticing. The allied partnerships we profiled in our uncrewed maritime systems installment like UFORCE, maker of Ukraine’s Magura strike craft, teaming with U.S. company RECONCRAFT and Saronic’s strategic partnership with Samsung Heavy Industries, satisfy the country-of-production tests described above and therefore are attractive alternatives to merely importing products. Expect the same partnership wave in robotics: for allied manufacturers of humanoids, quadrupeds, and AMRs, a U.S. production joint venture is now the most direct route through the Covered List gate. These structures carry their own regulatory freight (e.g., ITAR/EAR classification and licensing, FOCI analysis, and CFIUS jurisdiction questions) but those issues can be worked through with knowledgeable counsel.

Practical Takeaway

Robotics and inverter manufacturers are now a covered industry, and drone rules are the template regulators will keep reaching for as restrictions extend to other autonomous systems. The strategic implication of years of continuity, and seven months of acceleration, is straightforward: treat these requirements as permanent features of the landscape and invest accordingly.

  1. Bill of Materials: Map the bill of materials to the component level by country of production, not supplier nationality. The governing tests ask where the device was produced, not who produced it.
  2. Processes for Compliance: FAR 52.240-1 obligates contractors to search SAM’s FASC list before proposing or using any UAS in performance; pair that with 1260H and Consolidated Screening List checks, build all three into procurement workflow, and flow the requirements down.
  3. Certifications Cannot Be Done Lightly: FAR 52.240-1 representations and FCC “not produced in a foreign country” certifications can carry False Claims Act and FCC enforcement exposure. Document your diligence contemporaneously.
  4. Strategize your Compliance: Choose your exemption pathway and then be careful to execute as planned. Blue UAS listing, reachable directly through DCMA or via AUVSI’s Green UAS certification, is the durable safe harbor for NDAA-compliant drones; relevant Buy American qualification and the exemptions are good through January 1, 2028; and Conditional Approvals persist only while the manufacturer follows its approved onshoring plan and passes ongoing vetting. For every new model in the pipeline — drone or robot — assess FCC authorization exposure early, and strategize how to comply early.
  5. Use the Section 833 Window: If a contractor can illuminate its supply chain and disclose noncompliant sources promptly it can benefit while the interim national security waiver authority runs through January 1, 2028.

What’s Next

The only certainty in this environment is continued tightening of supply chain security in key industries.  Categorical exemptions for robotics, on the Blue UAS model, may follow as they did for drones, and the January 1, 2028 exemption horizon could be extended again, allowed to lapse as domestic capacity matures, or codified by Congress into something more permanent—but, under any of these scenarios, a decision to onshore as much of your supply chain as possible will likely pay off.

China cornered the robotics and drone markets by building the supply chains that the world would rely on. Washington’s answer, years in the making and now accelerating category by category, is to compel a new set of producers to be built at home. Whether this will ultimately work from a policy perspective is unclear, but what is clear is that contractors seeking to do business with the U.S. Government will need to find ways to comply with the increasing emphasis on security in supply chains.  In navigating these complicated and ever-changing regulations Fluet’s Government Contracts and International Trade teams bring experience and business acumen in order to counsel drone, robotics, and autonomy companies, their suppliers, and their investors toward success.