ARTICLE
28 January 2026

BIS Updates Export Controls For Certain UAVs

CL
Cassidy Levy Kent

Contributor

Cassidy Levy Kent is an international law firm with offices in Washington, Ottawa, and Brussels. Our practice is focused on helping our clients address international trade and investment issues — whether they involve trade controls, trade remedy litigation, dispute settlement proceedings under the World Trade Organization (WTO) and bilateral and regional free trade agreements and investment treaties, or negotiations and other policy efforts. The lawyers at Cassidy Levy Kent have decades of experience as partners in the international trade and investment practices at some of the largest, and most prestigious, law firms in Canada, Europe, and the United States.
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).
United States International Law
Ulrika K. Swanson’s articles from Cassidy Levy Kent are most popular:
  • with readers working within the Banking & Credit industries
Cassidy Levy Kent are most popular:
  • within Finance and Banking and Technology topic(s)

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.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

[View Source]

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More