The U.S. Department of Commerce’s Bureau of Industry and Security published on January 21 an interim final rule (IFR) revising the export controls that apply to certain civil unmanned aerial vehicles (UAVs). Issued to further the objectives of Executive Order 14307, “Unleashing American Drone Dominance,” the IFR makes two significant changes to the licensing requirements in the Export Administration Regulations (EAR) for certain UAVs. These changes are designed to align with the reality of the commercial UAV market and help facilitate the export of U.S.-manufactured UAVs.
First, UAVs that are classified under Export Control Classification Number (ECCN) 9A012.a.1 are now subject to National Security Column 2 (NS2) controls instead of NS1 controls. As a result, commercial UAVs that have a maximum endurance of less than one hour and are designed to take off and have stable controlled flight in wind gusts equal to or exceeding 46.3 km/h will no longer require a license for export or reexport to countries in Country Group A:1 (the Wassenaar Arrangement Participating States). Prior to this change, these UAVs were only eligible for export or reexport to the United Kingdom, Australia, and Canada without a license.
Second, certain UAVs that are classified under ECCNs 9A012 and 9A120 are now eligible to be exported or reexported to countries in Country Group A:5 under License Exception Strategic Trade Authorization (STA). This includes long-range cargo delivery and agricultural spraying drones that were previously excluded from the STA license exception because they are subject to Missile Technology Column 1 (MT) controls. This revision makes certain UAVs eligible for the STA license exception, provided that they are not capable of delivering at least a 500 kg payload to a distance of at least 300 km.
These changes significantly expand the number of countries to which certain U.S.-manufactured UAVs can be exported or reexported without a license. Comments on this IFR may be submitted through Regulations.gov (Docket Number BIS–2025–0092) through February 19, 2026.
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Cassidy Levy Kent’s attorneys, compliance professionals, economists, and licensed customs brokers assist clients navigating export controls and sanctions issues. We expect further developments in this space and will continue to provide updates. Please contact us with any questions.