Updates to NDAA Compliance and BlueUAS

Updates to NDAA Compliance and BlueUAS

The Fiscal Year 2023 National Defense Authorization Act (NDAA) Section 817, signed into law on December 23, 2022, introduced stricter procurement regulations for unmanned aircraft systems (UAS) used in national security applications. Under this provision, any UAS deployed for mission-critical government operations must not contain critical components manufactured in a “covered” country.

This update has significant implications for drone builders, system integrators, and component suppliers across the defense and commercial UAS supply chain. Understanding which components fall under NDAA Section 817 and how to verify supplier compliance is now a core requirement for any organization pursuing U.S. Department of Defense contracts.

What Fiscal Year 2023 NDAA Section 817 Requires

NDAA Section 817 establishes that UAS systems used for applications critical to national security must not be manufactured in a covered country. The regulation applies to complete drone systems as well as individual critical components integrated into those systems.

Covered Countries

The legislation identifies four covered countries:

• People’s Republic of China

• Russian Federation

• Islamic Republic of Iran

• Democratic People’s Republic of Korea

Covered UAS Entities

The following categories of companies fall under the covered designation:

• Da-Jiang Innovations (DJI) and all subsidiaries

• Any entity listed on the U.S. Department of Commerce Consolidated Screening List

• Companies domiciled in a covered country or subject to influence, direction, or control by a covered nation’s government

Nine Critical Component Categories

Section 817 defines nine categories of critical UAS components that must originate from non-covered sources:

1. Flight controllers

2. Radios

3. Data transmission devices

4. Cameras

5. Gimbals

6. Ground control systems

7. Operating software

8. Network connectivity

9. Data storage

Ethernet switches and embedded networking hardware qualify as both “data transmission devices” and “network connectivity” components under this classification. Any Ethernet infrastructure integrated into a defense-grade UAS platform must therefore meet NDAA compliance requirements to be eligible for government procurement.

How BotBlox Hardware Meets NDAA Compliance

BotBlox embedded Ethernet switches and networking products are designed and manufactured to meet NDAA Section 817 compliance requirements. Compliance is verified through three structural factors that span ownership, manufacturing, and component sourcing.

UK Headquarters with Sole UK Ownership
BotBlox Systems operates under Kapek Ltd, a company registered in the United Kingdom with no foreign ownership ties to any covered country. Full ownership documentation is available upon request for procurement compliance verification.

Manufacturing in Thailand and the United Kingdom
All BotBlox products are manufactured exclusively in Thailand and the UK. No production, assembly, or final testing takes place in China, Russia, Iran, or North Korea. Manufacturing partners are vetted and audited to maintain supply chain compliance.

Component Sourcing Outside Covered Countries
Nearly all electrical components used in BotBlox hardware are sourced from non-Chinese suppliers. BotBlox maintains detailed bills of materials with country-of-origin data for each component, enabling procurement teams to verify compliance at the part level.

BotBlox provides Certificates of Conformity and country-of-origin documentation for all products in the NDAA Compliant Series. These documents are available for download from the BotBlox documentation portal and can be submitted as part of procurement compliance packages for government contracts.

BotBlox and the BlueUAS Program

The Blue UAS program, operated by the Defense Innovation Unit (DIU), is a vetting and certification process for commercial UAS technology intended for use by the U.S. Department of Defense. The program evaluates complete drone systems for security, reliability, and supply chain compliance before approving them for DoD procurement.

BlueUAS certification applies exclusively to full drone system manufacturers. Component suppliers such as BotBlox are not eligible for direct certification through the program.

However, BotBlox NDAA-compliant Ethernet switches are already integrated into multiple BlueUAS-certified drone platforms. Several certified manufacturers rely on BotBlox networking hardware as part of their compliant onboard data infrastructure. Using pre-verified NDAA-compliant components simplifies the documentation and audit process for system integrators pursuing BlueUAS approval.

What This Means for UAS System Integrators

For engineering teams and procurement managers building UAS platforms for defense or government applications, the key considerations are:

• All nine categories of critical components must originate from non-covered countries under NDAA Section 817

• Ethernet switches and embedded networking hardware are explicitly covered as “data transmission devices” and “network connectivity” components

• BotBlox products meet NDAA requirements through UK ownership, non-covered-country manufacturing, and verified component sourcing with full traceability

• BlueUAS certification targets complete systems, but using NDAA-compliant components at the subsystem level streamlines the overall certification path

• Certificates of Conformity and country-of-origin documentation should be requested from all component suppliers and retained as part of the compliance record

For questions about NDAA compliance documentation or to request Certificates of Conformity for specific BotBlox products, contact the BotBlox team at info@botblox.io.

References

• NDAA Fiscal Year 2023, Section 817 (U.S. Congress)

• Consolidated Screening List (U.S. Department of Commerce)

• Blue UAS Cleared List (Defense Innovation Unit)