Every few weeks another robotics or drone vendor announces that production is moving — to Vietnam, to Mexico, to a new US line. Buyers read those announcements as compliance news. In 2026 they mostly are not, because the rules that decide what a US buyer may install are written in units of *parts and percentages*, and relocation announcements are written in units of *factories*.
Here is what the rules actually say, and what our own price records show about where de-risking is really happening.
The FCC rule does not care whose company it is
On 21 December 2025 a National Security Determination was issued, and on 22 December the FCC's Public Safety and Homeland Security Bureau added all foreign-produced uncrewed aircraft systems and UAS critical components to the Covered List, via Public Notice DA-25-1086 (per the Wiley alert). The determination's list of "critical components" is long and specific: "data transmission devices, communications systems, flight controllers, ground control stations and UAS controllers, navigation systems, sensors and cameras, batteries and battery management systems, motors" and associated software.
The decisive wording is about geography, not ownership. As Pillsbury's summary puts it, "the nationality of the entity producing UAS or UAS critical components is not a relevant consideration" — the prohibition applies to all foreign production, including a US company manufacturing abroad.
Read that against a relocation announcement. A Shenzhen-to-Hanoi move changes the country and not the category: the product is still foreign-produced. The exits are narrow and dated — equipment authorized before 22 December 2025, items on the Blue UAS Cleared List, and products meeting the Buy American "domestic end product" standard of 65% US component cost — and per Pillsbury the latter two are limited to 1 January 2027. Meanwhile DJI and Autel carry an additional problem: under Section 1709 of the FY2025 NDAA they are named entities, so, as Wiley notes, restrictions reach them "even if production moved domestically."
Our view: for most vendors the compliance question is not "did you leave China" but "what share of this bill of materials is American, and can you evidence it." Those are different projects with different budgets, and only one of them makes a good press release.
Vietnam is not a tariff exit either
We reported on 1 August that the Section 301 forced-labour action effective 24 July 2026 set 12.5% for both China and Vietnam, with 17 other countries at 10%. The most-used China Plus One destination therefore carries the identical rate on that action. Relocation can still change other duty exposure, and USMCA treatment makes Mexico a genuinely different case — but "we moved to Vietnam" is not, by itself, an answer to a tariff question. Ask which specific duty a move eliminates.
The layer that actually resists relocation
Motors and batteries are on the FCC's critical-components list, and motors lead back to magnets, which is where relocation is slowest and the policy calendar most crowded.
On 9 October 2025 China issued Announcements 55–58, 61 and 62, which included an extraterritorial licensing obligation on foreign-made products containing Chinese rare-earth material. MOFCOM Announcement No. 70 (7 November 2025) suspended those directives and Announcement No. 72 (9 November 2025) suspended the enhanced US-specific controls until 27 November 2026 (Clark Hill). Note what was paused: precisely the rule that follows the material across borders into someone else's factory. It is suspended, not repealed, and it has a date on it. Still permanently in force are Announcement 18 (2025), which added seven medium and heavy rare-earth elements to the Dual-Use Items Control List, and Article 1 of Announcement 46 (2024), which prohibits dual-use exports to US military end users.
From the other direction, DFARS 252.225-7052 currently restricts, for NdFeB magnets, the melting step and "all subsequent phases of production." Effective 1 January 2027 it extends to the "entire supply chain from mining of neodymium, iron, and boron through production of finished magnets" for covered countries including China.
Our view: a motor assembled in a third country from Chinese-melted NdFeB satisfies neither regime after that date, and no factory address fixes it. If a supplier's de-risking story stops at final assembly, it has not started on the part that the 2027 rules are about.
What de-risking looks like when it is real, and priced
Our 11 August price survey caught it as an explicit line item. Freefly's Astro Max is $22,995 standard and $28,995 in NDAA/Blue configuration; the Alta X Gen 2 is $39,650 and $45,650. The delta is exactly $6,000 on both aircraft, and the manufacturer's own knowledge base explains why: "The radio link is what determines NDAA compliance" — the standard build uses a Chinese-made Herelink radio, the Blue build a Doodle Labs unit. The confirmation is in what does *not* change: the same Alta X armour is $5,495 in both versions.
That is the shape of genuine component substitution. One part, one price, and it shows up on a shelf where anyone can check it.
Where relocation is real — and about something else
On the consumer side the moves are genuine. Roborock "launched its original equipment manufacturer production in Vietnam in the fourth quarter of 2024," making it, per China Daily, the first Chinese robot-vacuum maker to establish overseas OEM production; Dreame "is already working on setting up factories in Asia." Those are tariff and logistics decisions in a category with no Covered List problem — and, as we documented on 1 August, tariff changes in that category did not reach retail as tariff-shaped price moves anyway.
Five questions to ask a vendor in 2026
- Which specific duty or rule does your move eliminate — and which does it leave untouched?
- What is your US component cost percentage, and would it clear the 65% Buy American threshold?
- Which of the FCC's listed critical components (radio, flight controller, camera, battery, motor) have actually been resourced, and to whom?
- Where are your magnets melted, and what is your plan for 1 January 2027?
- Is your current legal position an exemption with an expiry date, or a compliant bill of materials?
Sources
- Wiley, "In Unexpected, First-of-Its-Kind Action, FCC Adds All Foreign-Produced Uncrewed Aircraft Systems and UAS Critical Components to Covered List" — https://www.wiley.law/alert-In-Unexpected-First-of-Its-Kind-Action-FCC-Adds-All-Foreign-Produced-Uncrewed-Aircraft-Systems-and-UAS-Critical-Components-to-Covered-List
- Pillsbury, "FCC Implements Categorical Prohibition on All Foreign-Produced UAS and UAS Critical Components" — https://www.pillsburylaw.com/en/news-and-insights/fcc-categorical-prohibition-foreign-produced-uas-critical-components.html
- Clark Hill, "China Hits 'Pause' on Rare-Earth Export Controls and What it Means for Supply Chains" — https://www.clarkhill.com/news-events/news/china-hits-pause-on-rare-earth-export-controls-and-what-it-means-for-supply-chains/
- DFARS 252.225-7052, Restriction on the Acquisition of Certain Magnets, Tantalum, and Tungsten — https://www.acquisition.gov/dfars/252.225-7052-restriction-acquisition-certain-magnets-tantalum-and-tungsten.
- China Daily HK, "Chinese robot vacuums sweep Southeast Asia" — https://www.chinadailyhk.com/hk/article/630516
- GrabaRobot, Blue UAS / NDAA drone price guide (11 August 2026) and Who actually paid the tariff (1 August 2026)
