Federal Prohibition on Certain UAS in Federally Funded Research
Effective December 22, 2025, researchers are prohibited from procuring, operating, or otherwise using unmanned aircraft systems (UAS) (e.g. drones) manufactured or assembled by covered foreign entities when performing work under any federally funded contracts, grants, or cooperative agreements.
Prohibited Drones
Under the American Security Drone Act of 2023, drones manufactured or assembled by covered foreign entities may not be used in federally funded research. These entities include, but are not limited to:
- DJI (Shenzhen DJI Innovation Technology Co. Ltd.)
- Autel Robotics Co., Ltd.
- Aerospace CH UAV Co., Ltd.
- Chengdu JOUAV Automation Tech Co., Ltd. (JOUAV)
Key Compliance Considerations
1. Use of Parts from Covered Foreign Entities
- If you build your own drones, discontinue purchasing components from covered foreign entities by December 22, 2025.
- If your current equipment includes parts from these manufacturers, or if you need guidance on a specific situation, email export@unh.edu.
2. Preliminary Testing, Calibration, or Training
- After the prohibition date, any use of a covered foreign entity drone for a federally funded project is not allowed—even for testing, training, or other non-research activities.
- Example: Using a DJI drone for flight training before switching to a compliant model still violates the prohibition.
3. Previously Collected Data
- Data collected before December 22, 2025 may continue to be used unless the sponsor specifies otherwise.
- No additional data collection using prohibited drones may occur after the prohibition takes effect.
Identifying Compliant Alternatives
To ensure compliance, the DOD has published a list of drone manufacturers that have been cleared by the federal government. After December 22, 2025, drones must be purchased from one of the companies listed on the Blue UAS Cleared List to avoid any violations.
Applicability Beyond Federally Funded Research
The prohibition applies only to federally funded contracts, grants, and cooperative agreements. It does not apply to:
- Non-federally funded projects (e.g., industry-sponsored or internally funded research)
- Personal use
- Educational or teaching activities not associated with federally sponsored research
However, researchers may still wish to follow federal standards for consistency, risk management, and future project readiness. All UAS operations must comply with university policy as well as applicable federal, state, and local regulations governing safety, security, and airspace use.
Victor Sosa, Director
Contracts & Export Controls
Phone: (603) 862-2001
Email: victor.sosa@unh.edu
Melissa McGee, Assistant Director
Research Integrity Services
Phone: (603) 862-2005
Email: melissa.mcgee@unh.edu
