Prohibiting the Importation and Marketing of Certain Covered UAS and UAS Critical Components and Equipment Listed in Section 1709 of FY2025 NDAA

Introduction In recognition of the national security risks posed by certain drone platforms, the Federal Communications Commission (FCC) added both foreign-produced drones and specific equipment and services produced by DJI and Autel Robotics to the Covered List. The FCC is now investigating whether other companies are circumventing these restrictions by covertly selling drones containing DJI parts into the domestic market. Eight firms — Cogito, Lyno Dynamics, Fikaxo, WaveGo Tech, Knowact Robot, Skyhigh Tech, Spatial Hover, and Xtra — all received Notices of Apparent Liability on July 10 proposing fines for failing to respond to the commission’s Enforcement Bureau regarding potential Covered List violations.[1] Separately, one other firm, XAG, displays ties to firms identified as being embedded within China’s military industrial base and markets foreign-produced drone platforms in the United States. This raises concerns over its equipment authorization status under subsequent Covered List actions.[2] In response to credible allegations of wrongdoing and to safeguard U.S. national security, the FCC should prohibit the continued importation and marketing of these firms’ equipment in the United States. Many Targeted Firms Seemingly Share Key Characteristics With DJI and Autel There is strong circumstantial evidence to suggest that several of these firms fall under the jurisdiction of Section 1709 of the FY25 National Defense Authorization Act by incorporating DJI and Autel components currently on the Covered List. The government is currently investigating whether several firms that allegedly incorporated DJI components placed on the Covered List should maintain access to the American market. According to an independent review of the FCC’s database of listed frequency pairings, Cogito, Lyno Dynamics, Fikaxo, WaveGo Tech, Knowact Robot, and Skyhigh Tech all filed for specific paired frequencies within the 5745.5-5829.5 MHz band also common across DJI’s commercial products.[3] While it is possible that this similarity is coincidental, it also heavily suggests these drones each carry a similar frequency configuration to DJI’s proprietary OcuSync chipset, which broadcasts on an identical frequency at an identical cycle to those filed by the alternate firms.[4] Beyond broadcasting on identical frequencies, each of these firms’ products share other characteristics with prohibited DJI and Autel products. Cogito’s systems, including its flight time, camera, range, and software — the same product categories currently on the Covered List — are nearly identical to DJI’s Air 3 model despite DJI never publicly confirming a licensing agreement.[5] These allegations were cited by congressional investigators in a letter to then-Commerce Secretary Gina Raimondo, which also identified Cogito’s internal code containing references to DJI as its manufacturer.[6] The comparison of Cogito to DJI is explicit in Cogito’s advertising, which openly refers to its products as offering “DJI-level drone performance” and being built with “DJI-grade hardware” while claiming to have licensed portions of DJI’s technologies.[7] Independent industry analysis suggests that both Fikaxo and Spatial Hover also sold near-identical copies of DJI products, particularly the DJI Mavic 3 Enterprise, which allegedly contained prohibited video and surveillance equipment.[8] After public reporting tied a Fikaxo drone to DJI, one of the firm’s products was shortly thereafter sold under the auspices of Spatial Hover, which applied for a new FCC license.[9] Fikaxo’s corporate records show that the firm was registered only months before DJI was added to the Covered List and that its website featured content from Autel Robotics, another Chinese firm whose equipment is on the Covered List.[10] Xtra’s camera systems are also nearly identical to DJI’s offerings, with its advertising openly hinting that its product lines are a match to DJI’s Pocket and Pro series, respectively, with the tagline “from Pocket to Pro.”[11] These similarities were confirmed by an FCC tear-down of DJI’s Osmo Pocket 3 and independent security assessments, which highlighted that Xtra’s products contained identical boards and chips, app source code, and references to other DJI products within the codebase itself.[12] Mirroring Fikaxo, Xtra registered with the FCC as a Delaware-based firm immediately ahead of FY25 National Defense Authorization Act (NDAA) passage.[13] In contrast, Guangzhou Xaircraft Technology Co., Ltd. (XAG) poses a national security threat due to its public connections to the Chinese state and firms linked to the Chinese military. In a 2019 interview, XAG cofounder Justin Gong publicly admitted that XAG (then known as Xaircraft) had at least considered cooperating in an unspecified manner with the People’s Liberation Army.[14] In 2020, XAG allegedly received funding from Baidu, a firm the Department of Defense has identified as a Chinese military company, complementing additional financing from several Chinese state-linked funds.[15] In registering its trademark with the U.S. Patent and Trademark Office in 2019, XAG also noted “military drones” among its filings, further highlighting its connections to the defense industry, another emerging area of FCC scrutiny.[16] XAG is also deeply tied to Xinjiang, having been deployed to develop an unmanned “model farm” intended to showcase novel methods to expand cotton production that was cited in state media as aligning with Beijing’s 15th Five-Year Plan.[17] Recommendations The FCC has strong legal and procedural justification for revoking these firms’ prior equipment authorizations to prevent their importation and marketing within the United States. The commission has previously highlighted the severe national security risks posed by both the foreign-produced unmanned aerial systems and the specific video and surveillance equipment and services listed by Section 1709 of the FY2025 NDAA. Section 1709 notes that any subsidiary, affiliate, or partner of DJI or Autel, along with any entity under a joint venture or a technology-sharing or licensing agreement with either firm, may qualify for inclusion on the Covered List — a definition that seems to substantially cover all the commission’s listed firms but XAG.[18] Even in the absence of a publicly acknowledged relationship, public assessments of these firms’ products, along with their corporate structure, strongly suggest that they either incorporate DJI- or Autel-produced components or maintain a technology-sharing arrangement with these firms. In addition, XAG’s public record suggests that it maintains ties with a foreign adversary, including Chinese military companies and funds linked to the Chinese state.[19] Moreover, the FCC maintains a strong basis for revoking previous equipment authorizations on national security grounds under the Secure Networks Act and its previous rulemaking connected to Covered List entities and sectors. As the commission has noted, previously authorized equipment produced by Covered List entities is often “functionally identical” to their newer, already banned equipment and thus poses a similar risk profile, grounding the FCC’s actions as fulfilling its national security mandate.[20] The FCC should bar the importation and marketing of all covered equipment produced by Cogito Tech Company, Limited (Cogito); Fikaxo Technology Inc. (Fikaxo); Lyno Dynamics LLC (Lyno Dynamics); Skyhigh Tech LLC (Skyhigh Tech); Spatial Hover Inc. (Spatial Hover); SZ Knowact Robot Technology Co., Ltd. (Knowact Robot); WaveGo Tech LLC (WaveGo); and Xtra Technology LLC (Xtra) that falls under Section 1709 of the FY2025 NDAA. There is strong public evidence to suggest these firms import or market products that contain equipment currently on the Covered List. In either case, revoking their previously issued equipment authorizations will strengthen U.S. national security by preventing components that could pose an unacceptable threat from entering the domestic market. The FCC should bar the importation and marketing of all covered equipment produced by Guangzhou Xaircraft Technology Co., Ltd. (XAG). XAG produces its components within a foreign country and has publicly discussed its ties to the Chinese military and the Chinese state, both factors that ensure its eligibility for Covered List designation. The FCC should establish a continuing anti-circumvention review for new equipment-authorization applications. The commission should require that all applicants disclose all “electrically identical” products to cross-reference these products in the event of a revocation of their authorizations. Moreover, applications involving common hardware, firmware, software infrastructure, test laboratories, importers, or corporate representatives should receive heightened scrutiny and should be required to disclose the equipment’s complete manufacturing and technological provenance. Conclusion The FCC maintains both the statutory authority and executive mandate to safeguard U.S. national security by enforcing Covered List restrictions, including by prohibiting the importation and marketing of such products through the revocation of previously issued equipment authorizations. Eight of the nine firms listed by the commission face credible allegations of maintaining relationships with either DJI or Autel Robotics, while the other firm has publicly displayed ties to the Chinese state and Chinese military. While these revocations may be a major regulatory landmark and raise legal challenges, they would also demonstrate the commission’s commitment to its national security mission and the enduring strength of its longstanding efforts to establish secure technology supply chains. Moreover, the commission has already explicitly noted its authority to revoke equipment authorizations in response to security concerns that emerged following a Covered List designation — the exact risk profile demonstrated by these firms. Thank you for considering our comments. We look forward to seeing how our input is incorporated into the commission’s ongoing policy work. [1] U.S. Federal Communications Commission, Enforcement Bureau, “FCC Proposed Fines for Failure to Respond to Investigative Requests,” July 10, 2026. (https://www.fcc.gov/document/fcc-proposed-fines-failure-respond-investigative-requests) [2] U.S. Federal Communications Commission, “Public Safety and Homeland Security Bureau and Office of Engineering and Technology Prohibit the Importation and Marketing of Previously Authorized Covered Communications Equipment Added to the Covered List in 2024 or Earlier,” June 26, 2026. (https://docs.fcc.gov/public/attachments/DA-26-635A1.pdf); Tate Nurkin, Christian Le Miere, Chris Eusebi, Stephen Rodriguez, Hassan Almaala, and Andrew Gonzales, “China’s Remote Sensing,” OTH Intelligence Group, prepared for the U.S.-China Economic and Security Review Commission, December 2024. (https://www.uscc.gov/sites/default/files/2024-12/Chinas_Remote_Sensing.pdf); U.S. Department of Defense, “Entities Identified as Chinese Military Companies Operating in the United States in Accordance with Section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021,” June 8, 2026. (https://media.defense.gov/2026/Jun/08/2003945537/-1/-1/1/ENTITIES-IDENTIFIED-AS-CHINESE-MILITARY-COMPANIES-OPERATING-IN-THE-UNITED-STATES-IN-ACCORDANCE-WITH-SECTION-1260H.PDF) [3] Haye Kesteloo, “Drone Detective Bot Tracks DJI-Linked Companies Through Wireless Frequency Fingerprints,” DroneXL, October 29, 2025. (https://dronexl.co/2025/10/29/drone-detective-bot-tracks-dji-linked-companies) [4] Ibid. [5] Brad Dress, “China’s dominant drone industry is a step ahead of Congress,” The Hill, June 12, 2024. (https://thehill.com/policy/defense/4714269-chinas-dominant-drone-industry-is-a-step-ahead-of-congress) [6] U.S. House Select Committee on the Strategic Competition Between the United States and the Chinese Communist Party, “Letter to Secretary of Commerce Gina Raimondo,” August 20, 2024. (https://chinaselectcommittee.house.gov/sites/evo-subsites/selectcommitteeontheccp.house.gov/files/evo-media-document/2024-08-20%20-%20DOC%20Anzu%20%2B%20Cogito%20Letter.pdf) [7] “Specta Drones Manufacturer,” Specta, accessed July 23, 2026. (https://spectadrone.com) [8] Haye Kesteloo, “Spatial Hover Emerges as Newest DJI Shell Company After Fikaxo Drone Mysteriously Migrates Between Websites,” DroneXL, October 3, 2025. (https://dronexl.co/2025/10/03/spatial-hover-dji-shell-company-after-fikaxo-drone) [9] Haye Kesteloo, “Drone Detective Bot Tracks DJI-Linked Companies Through Wireless Frequency Fingerprints,” DroneXL, October 29, 2025. (https://dronexl.co/2025/10/29/drone-detective-bot-tracks-dji-linked-companies) [10] Ibid; Haye Kesteloo, “Spatial Hover Emerges as Newest DJI Shell Company After Fikaxo Drone Mysteriously Migrates Between Websites,” DroneXL, October 3, 2025. (https://dronexl.co/2025/10/03/spatial-hover-dji-shell-company-after-fikaxo-drone) [11] Haye Kesteloo, “FCC Fines Eight Alleged DJI Front Companies $25,000 Each for Stonewalling Investigators,” DroneXL, July 14, 2026. (https://dronexl.co/2026/07/14/fcc-fines-dji-front-companies-25000) [12] Sean Hollister, “Xtra: the company that lets DJI sneak its popular cameras into the US/The popular DJI Osmo Pocket 3 is among the cameras this shady startup sells,” The Verge, October 9, 2025. (https://archive.ph/Ms824) [13] Ibid; Haye Kesteloo, “Drone Detective Bot Tracks DJI-Linked Companies Through Wireless Frequency Fingerprints,” DroneXL, October 29, 2025. (https://dronexl.co/2025/10/29/drone-detective-bot-tracks-dji-linked-companies) [14] Michelle Chan, “Chinese startup sows seeds of farm revolution with drones and AI,” Nikkei Asia (Japan), March 15, 2019. (https://archive.ph/IFEB5); “XAG,” SoftBank Group Corp., accessed August 5, 2026. (https://group.softbank/en/philosophy/dreams/food-and-farming/xag) [15] Tate Nurkin, Christian Le Miere, Chris Eusebi, Stephen Rodriguez, Hassan Almaala, and Andrew Gonzales, “China’s Remote Sensing,” OTH Intelligence Group, prepared for the U.S.-China Economic and Security Review Commission, December 2024. (https://www.uscc.gov/sites/default/files/2024-12/Chinas_Remote_Sensing.pdf); Coco Feng, “Agricultural drone maker XAG raises US$182 million in funding round led by Baidu, SoftBank,” South China Morning Post (China), November 16, 2020. (https://archive.ph/lT3eZ); U.S. Department of Defense, “Entities Identified as Chinese Military Companies Operating in the United States in Accordance with Section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021,” June 8, 2026. (https://media.defense.gov/2026/Jun/08/2003945537/-1/-1/1/ENTITIES-IDENTIFIED-AS-CHINESE-MILITARY-COMPANIES-OPERATING-IN-THE-UNITED-STATES-IN-ACCORDANCE-WITH-SECTION-1260H.PDF) [16] U.S. Patent and Trademark Office, Trademark Filing, “XAG” (Guangzhou Xaircraft Technology Co., Ltd.), Serial Number 79251878, accessed July 23, 2026. (https://tmsearch.uspto.gov/search/search-results/79251878); U.S. Federal Communications Commission, Fact Sheet, “FCC Takes Action to Secure the Drone Supply Chain,” July 21, 2026. (https://www.fcc.gov/document/fcc-takes-action-secure-drone-supply-chain) [17] “China Focus: Xinjiang’s smart farming revolution on cotton fields,” Xinhua News Agency (China), May 9, 2026. (https://archive.ph/Ccivk) [18] Servicemember Quality of Life Improvement and National Defense Authorization Act for Fiscal Year 2025, Pub. L. 118-159, §1709, 138 Stat. 1773, 2209-2210. (https://www.govinfo.gov/app/details/PLAW-118publ159) [19] Tate Nurkin, Christian Le Miere, Chris Eusebi, Stephen Rodriguez, Hassan Almaala, and Andrew Gonzales, “China’s Remote Sensing,” OTH Intelligence Group, prepared for the U.S.-China Economic and Security Review Commission, December 2024. (https://www.uscc.gov/sites/default/files/2024-12/Chinas_Remote_Sensing.pdf); Coco Feng, “Agricultural drone maker XAG raises US$182 million in funding round led by Baidu, SoftBank,” South China Morning Post (China), November 16, 2020. (https://archive.ph/lT3eZ); U.S. Department of Defense, “Entities Identified as Chinese Military Companies Operating in the United States in Accordance with Section 1260H of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021,” June 8, 2026. (https://media.defense.gov/2026/Jun/08/2003945537/-1/-1/1/ENTITIES-IDENTIFIED-AS-CHINESE-MILITARY-COMPANIES-OPERATING-IN-THE-UNITED-STATES-IN-ACCORDANCE-WITH-SECTION-1260H.PDF) [20] U.S. Federal Communications Commission, “Public Safety and Homeland Security Bureau and Office of Engineering and Technology Prohibit the Importation and Marketing of Previously Authorized Covered Communications Equipment Added to the Covered List in 2024 or Earlier,” June 26, 2026. (https://docs.fcc.gov/public/attachments/DA-26-635A1.pdf)