NDAA compliance is a component-level rule, so a compliant drone is a compliant bill of materials. This guide walks a small-UAS BOM line by line: what the covered-country baseline requires of each part, where the Department of War's Drone Dominance Program supply-chain framework goes further and by when, what to ask a supplier, and examples of suppliers that describe themselves as domestic or non-covered-country. The examples are those suppliers' own statements, not our verification. The questions are how you verify.
Two bars, not one
The baseline is the NDAA covered-country requirement: no covered foreign entity anywhere in the part's supply chain, and documentation that proves it. It applies to every program that touches federal money through a contract, grant, or cooperative agreement, and primes flow it down to their suppliers.
The higher bar is the Drone Dominance Program Supply Chain Framework, Version 2, dated 23 July 2026. It is not a statute — it governs participation in that program — but it is the most specific component-by-component sourcing schedule DoD has published for small UAS, and it states its goal as a wholly domestic sUAS supply chain. Requirements tighten in dated phases: Phase 2 minimum (August 2026) is the floor for participation, Phase 3 minimum (February 2027) and Phase 4 (August 2027) tighten further, and each phase's preferred column becomes the next phase's minimum. Its vocabulary: NCC means non-covered country; ASDA means the American Security Drone Act and its list of covered foreign entities; OCM means the original component manufacturer.
The framework is also candid about cost. In its own words: components from non-covered countries "will be more expensive, at least initially," and "it is actual demand for compliant components that will drive their costs down over time." That is the customer telling its suppliers why the premium exists and what removes it.
The bill of materials
1. Flight controller / autopilot
Covers: processor, IMU, sensors, the FC board, passives, and the autopilot firmware.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly; no Section 889 components; ASDA-compliant entity; electronic parts from OCMs or authorized distributors.
- Phase 3 minimum: non-covered-country assembly and PCB; firmware source repository not hosted in or administered from a covered foreign country.
- Phase 4 preferred: US assembly; US or nearshored PCB; firmware repository hosted and controlled by a US entity and auditable on request.
Ask the supplier: Where was the board assembled and where was the PCB fabricated? Where is the firmware repository hosted, and who controls it?
Examples of non-covered-country sources, as they describe themselves: ARK Electronics' flight controller and Auterion's Skynode S were both selected under the Blue UAS Framework, per DIU's published list; ModalAI, of San Diego, describes its VOXL boards as US-made.
2. Communications and data link
Covers: telemetry radio, video transmitter and receiver, RF transceiver ICs, antenna, board, encryption module, and comms firmware.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly; no Section 889 components; ASDA-compliant; parts from OCMs or authorized distributors.
- Phase 3 minimum: non-covered-country assembly, RF ICs and PCB; any encryption module from a non-covered-country source; encryption and comms firmware repositories hosted and controlled by a US entity.
- Phase 4 preferred: US or nearshored assembly, RF semiconductors and PCB.
Ask the supplier: Where are the RF ICs made? Who controls the firmware and encryption repositories?
Examples of non-covered-country sources, as they describe themselves: Doodle Labs' transceivers and Mobilicom's Skyhopper radios are on DIU's Blue UAS Framework list.
3. GNSS module
Covers: receiver IC, board, passives, and GNSS firmware.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly; not from an ASDA-covered entity; no Section 889 components.
- Phase 3 minimum: non-covered-country receiver module and PCB; firmware repository hosted and controlled by a US entity.
- Phase 4 preferred: US or nearshored receiver module and PCB.
Ask the supplier: Where is the receiver module itself made, not just the carrier board?
Examples of non-covered-country sources, as they describe themselves: Locus Lock's GNSS receiver is on the DIU list; ARK Electronics sells GNSS modules it describes as NDAA-compliant; Hoverfly's Elements line builds its GPS modules on Septentrio chipsets, per Hoverfly's June 2026 announcement.
4. Electronic speed controllers
Covers: power MOSFETs, MCU, gate drivers, the ESC board, passives, and ESC firmware.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly; not from an ASDA-covered entity; parts from OCMs or authorized distributors.
- Phase 3 minimum: non-covered-country assembly, PCB, MCU and power semiconductors; firmware repository hosted and controlled by a US entity.
- Phase 4 preferred: US assembly; US or nearshored power semiconductors, MCU and PCB.
Ask the supplier: Where are the MOSFETs and MCU sourced, and from whom?
Examples of non-covered-country sources, as they describe themselves: Vertiq's ESC is on the DIU list, and Vertiq says its 81-08 G2 motor-and-ESC module was the first such combination approved under the Blue UAS Framework; Hoverfly Elements ESCs are built with Korea Robot Manufacturing, per Hoverfly.
5. Companion computer (if fitted)
Covers: processor, any AI/ML accelerator, board, and the embedded OS.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly and processor; no Section 889 networking components.
- Phase 3 minimum: software repository hosted and controlled by a US entity and auditable on request.
- Phase 4 preferred: US assembly; US or nearshored processor and PCB.
Ask the supplier: Which processor, fabricated where, and who controls the OS image?
Examples of non-covered-country sources, as they describe themselves: ModalAI's VOXL 2 and Auterion's Skynode S are the usual answers on Blue UAS platforms.
6. Other boards: Remote ID, power distribution, carriers
Covers: carrier boards, Remote ID transmitters, PDBs, interface boards, and their firmware.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly; Remote ID not manufactured in a covered foreign country; ASDA-compliant.
- Phase 3 minimum: non-covered-country PCB fabrication and assembly for all boards.
- Phase 4 preferred: US or nearshored fabrication and assembly for all boards.
Ask the supplier: Remote ID is the one buyers forget: where is that module made?
Examples of non-covered-country sources, as they describe themselves: Pierce Aerospace's B1 Remote ID beacon is on the DIU list; uAvionix describes its pingRID as US-manufactured.
7. Motors
Covers: magnets, rare-earth feedstock, stator, bearings, and housing. The framework notes that no current statute mandates non-Chinese motors for Group 1 sUAS — motor sourcing is a program requirement, and it is the one that bites hardest.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country motor assembly; specialty metals melted in the US or a qualifying country (10 USC 4863); ASDA-compliant entity. Phase 2 preferred adds a DFARS-compliant magnet sourcing plan.
- Phase 3 minimum: non-covered-country motor assembly, magnet production and winding; disclosed rare-earth feedstock origin.
- Phase 4 preferred: US or nearshored assembly and winding; non-covered-country magnet production and feedstock.
Ask the supplier: Where is the motor wound and assembled? Where are the magnets made, and where was the rare-earth feedstock mined and refined?
Examples of non-covered-country sources, as they describe themselves: KDE Direct says it manufactures industrial-grade motors in the US with supply-chain documentation; ePropelled builds motors in the US; Vertiq's 81-08 G2 is on the Blue UAS Framework; Hoverfly Elements motors are built with Korea Robot Manufacturing.
8. Propellers, airframe and structural components
Covers: propellers, carbon-fiber frame, molded parts, fasteners, canopy, wiring harness, and connectors.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly; specialty metals US or qualifying-country melted; ASDA-compliant entity.
- Phase 3 minimum: non-covered-country assembly and fabrication; non-covered-country frame materials, connectors and wiring.
- Phase 4 preferred: US or nearshored assembly, fabrication, frame materials, fasteners, connectors and wiring.
Ask the supplier: For a propeller: where is it molded, and where do the resin and reinforcement come from? For a frame: where is the carbon laid up and cut?
Examples of non-covered-country sources, as they describe themselves: Anvil Propulsion's line is domestic and built as drop-ins for the Gemfan and HQProp parts US platforms were designed around — see the Gemfan and HQProp replacement guides. Among other propeller makers, APC (Landing Products, Woodland, California) and Master Airscrew (Windsor Propeller, Rancho Cordova, California) both state that they design and manufacture in the USA.
9. Batteries and BMS
Covers: cells, pack assembly, BMS electronics and board, BMS firmware, and cathode and anode materials.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country pack assembly; not from entities on the Section 1260H list or the FY24 NDAA battery list (the framework names CATL); ASDA-compliant entity.
- Phase 3 minimum: non-covered-country pack assembly; non-covered-country cells compliant with the FY26 NDAA battery provision the framework cites; non-covered-country BMS assembly, board and active components.
- Phase 4 preferred: US pack assembly and US-manufactured cells, BMS assembly and PCB.
Ask the supplier: Where are the cells made, and where does the cathode material come from? Where is the pack assembled?
Examples of non-covered-country sources, as they describe themselves: Amprius says it will offer NDAA-compliant production pathways for its silicon-anode cells from spring 2026, including final assembly, with Nanotech Energy in Chico, California; 6K Energy supplies cathode material from North Andover, Massachusetts, under a seven-year agreement with CRG Defense reported by Manufacturing Dive.
10. Imaging and optics
Covers: EO cameras, IR and thermal sensors, image sensors, ISP, optics, board, camera firmware, and any gimbal.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country PCBA; no Section 889 components; ASDA-compliant entity.
- Phase 3 minimum: non-covered-country camera assembly, image sensor and PCB; camera firmware repository hosted and controlled by a US entity.
- Phase 4 preferred: US camera assembly; US or nearshored image sensor and PCB.
Ask the supplier: Where is the image sensor itself fabricated? That is the hard one.
Examples of non-covered-country sources, as they describe themselves: RPX Technologies' EmbIR camera and Greensight's UltraBlue and MicroBlue are on the DIU list.
11. Ground control system
Covers: GCS hardware and software, hand controller, boards, and encryption.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country assembly; no Section 889 components.
- Phase 3 minimum: non-covered-country assembly and PCB; all GCS software repositories hosted and controlled by a US entity; encryption modules from a non-covered-country source; a non-covered-country display.
- Phase 4 preferred: US hardware assembly; encryption meeting current DoD standards; non-covered-country manufacturing of all subcomponents.
Ask the supplier: Where is the controller assembled, and where is the display made?
12. Final assembly
Covers: assembling components and frame: motor mounting, wire routing, ESC and flight-controller installation, configuration, and pack-out.
Where the Drone Dominance framework goes:
- Phase 2 minimum: non-covered-country final assembly. Phase 2 preferred, and therefore Phase 3 minimum: US final assembly.
Ask the supplier: Where is the aircraft actually assembled and configured? Not where the brand is registered.
Five questions that work for every line
- Where was this part assembled, and where was its PCB fabricated?
- Which entity is the manufacturer, and does it appear on the FASC or Section 889 lists?
- For anything with firmware: where is the source repository hosted, and who controls it?
- For motors and batteries: where are the magnets and cells made, and where does the feedstock come from?
- Can you document all of that at the lot level — supplier declarations, material certificates, chain of custody?
A supplier who can answer those without hesitation is a supplier whose part will survive an audit. One who answers "NDAA-compliant" and stops there has told you the label, not the supply chain.
The propeller line, on this list
Anvil makes propellers domestically, in the sizes those platforms were designed around, each built to ship with a Component Passport carrying lot and serial traceability and material provenance. Row 8 above is our row. See the propeller line, the compliance overview, and, for sizes outside the standard line, custom programs.