The New Drone Reality: What EMS Leaders Need to Know About the FCC's Foreign UAS Ban

donniewoodyard
14 hours ago
7 min read

New Federal Regulatory Changes Fundamentally Reshape the Landscape for Public Safety Drone Operations

On December 22, 2025, the Federal Communications Commission issued a ruling that fundamentally changes how emergency medical services acquire and deploy unmanned aircraft systems.¹ In a sweeping action mandated by last year's (FY2025) National Defense Authorization Act, the FCC added all foreign-produced drones and their critical components to the agency's Covered List, effectively prohibiting these systems from receiving equipment authorizations required for legal operation in the United States.²

For EMS leaders who have embraced drone technology or are considering doing so, this presents both a challenge and an opportunity. Understanding the regulatory landscape, the national security imperatives driving these changes, and the strategic implications for your agency is now essential.

Why This Matters for EMS

Emergency medical services occupy a unique position in the American public safety ecosystem. EMS operates at the intersection of healthcare delivery and emergency response, routinely working in environments that involve critical infrastructure, mass gatherings, complex incidents, and sensitive operational data. As drones become more integrated into emergency response, this dual role increasingly places EMS operations within a broader national security context, particularly with respect to communications integrity, data protection, and operational resilience.

While the FCC's ruling may have appeared abrupt to some, it did not emerge in a vacuum. The mandate reflects more than eight years of sustained federal policy development focused on cybersecurity and supply chain risks associated with foreign-manufactured unmanned aircraft systems. That progression has mainly centered on Chinese manufacturers such as DJI, which has dominated a significant share of the global commercial drone market. The trajectory began in 2017 with a U.S. Army decision to permanently ground DJI drone fleets due to identified cyber vulnerabilities,³ followed by Department of Defense prohibitions,⁴ Treasury Department investment restrictions, and ultimately the explicit naming of DJI and Autel Robotics in the FY2025 National Defense Authorization Act.²

Viewed in this context, the FCC's December 2025 action represents the logical culmination of a long-standing federal policy direction rather than a sudden regulatory shift.

The National Security Rationale

The FCC's national security determination articulates several converging concerns that directly impact public safety operations:⁵

Data Vulnerability: China's 2017 National Intelligence Law compels Chinese companies to cooperate with state intelligence services.⁶ The 2021 Cyber Vulnerability Reporting Law requires Chinese companies to disclose vulnerabilities to Chinese authorities before public disclosure.⁷ For EMS agencies transmitting patient information, scene video, or operational data via drone systems, these legal frameworks create unacceptable risk.
Critical Infrastructure Protection: The United States will host the 2026 FIFA World Cup, America250 celebrations, and 2028 Olympics—all identified as high-priority protection targets.⁸ EMS agencies providing medical standby and emergency response at these events will be expected to operate with verified secure equipment.
Supply Chain Resilience: The National Security Strategy explicitly mandates "resilient and independent" domestic UAS manufacturing capability.⁹ Battlefield lessons from Ukraine and the Israel-Gaza conflict demonstrate how rapidly commercial drones can be weaponized or exploited for intelligence gathering.¹⁰
First Responder Mission Criticality: The national security determination explicitly recognizes the importance of UAS to first responders.⁵ Your role in emergency response is increasingly viewed through a national security lens—and with that comes heightened expectations for operational security.

What's Actually Banned

The scope extends beyond what many public safety leaders initially understood:¹

All foreign-produced UAS platforms, not just Chinese manufacturers
All UAS critical components produced abroad: data transmission devices, communications systems, flight controllers, ground control stations, navigation systems, sensors, cameras, batteries, battery management systems, and motors

Importantly, the FCC clarified that models already approved and currently in operational use are not immediately affected. Existing operations may continue. However, no new foreign-manufactured models can receive FCC equipment authorizations moving forward.¹¹

The Risk Calculation for Current Fleets

While your existing foreign-manufactured drones remain technically legal to operate, EMS leaders must make a strategic risk assessment. Consider:

Mission Sensitivity: Are you deploying drones for search-and-rescue operations in wilderness areas? Mass casualty incident documentation? Hazmat scene assessment? Vehicle extrication planning? Each use case has a different risk profile.
Data Security: What information is your drone transmitting? Patient images, incident scene video, tactical communications, and operational patterns all constitute potentially sensitive data.
Interoperability Requirements: Will you be expected to integrate with federal or state emergency operations that mandate verified-secure equipment? The trend is unmistakable.
Longevity Planning: Can you source replacement parts and maintain existing foreign platforms for the operational lifespan you require? Component availability may become constrained.

Several states—including Florida, Texas, Arkansas, Mississippi, and Tennessee—have already enacted state-level restrictions that compound federal requirements.¹² More will likely follow.

The Path Forward: Verified U.S. Partnerships

This national security-motivated regulatory change creates disruption, but it also creates a new opportunity for EMS agencies contemplating a drone program. The immediate challenge is that U.S.-manufactured alternatives typically cost two to five times more than the Chinese manufactured equivalents. However, this gap will narrow as domestic manufacturing scales and federal incentives support market development.

EMS leaders should take several concrete steps:

Conduct Supply Chain Audits: The Department of Defense maintains the Blue sUAS Approved Systems List, which catalogs drone platforms that have been independently evaluated and approved for federal government procurement under NDAA compliance standards. Even some manufacturers on this list source components globally, making supply chain verification essential.
Engage Verified U.S. Manufacturers: Companies like Skydio, Parrot USA, and others on the Blue sUAS list offer NDAA-compliant platforms designed specifically for public safety applications.¹³ Establish relationships now, before emergency procurement needs arise.
Explore Federal Funding: The regulatory shift is accompanied by federal support for domestic drone adoption. The Department of Homeland Security and other agencies are developing grant programs to help public safety agencies transition to compliant platforms.
Build Operational Partnerships: The Duke University program, which delivers AEDs during cardiac arrest calls in North Carolina,¹⁴ and the Archer First Response Systems 911-integrated program in Florida¹⁵ demonstrate the operational viability of medical drone delivery. As these established programs navigate supply chain compliance, their lessons learned can inform your planning.
Consider Dual-Use Applications: As your agency evaluates platforms, consider capabilities that support both day-to-day operations (e.g., accident scene documentation, wilderness search) and specialized missions (e.g., active threat response, hazmat assessment). Federal funding often favors multi-mission capable systems.

The Evolving Utility Landscape

This regulatory change arrives as drone utility in emergency medical services continues expanding. Beyond aerial photography and scene documentation, we're seeing:

Automated external defibrillator delivery during cardiac arrest calls
Naloxone deployment for overdose response
Tourniquet and hemorrhage control equipment for trauma incidents
Blood product transport to remote or disaster-affected areas
Real-time tactical intelligence for active threat incidents

The medical drone delivery services market is projected to grow from approximately $294 million in 2024 to $2.5 billion by 2034, a 24 percent compound annual growth rate.¹⁶ EMS agencies that establish compliant programs now will be positioned to capture operational and grant funding advantages as the sector matures.

Your Role in National Security

For generations, EMS operated primarily within a healthcare framework, but that's changing. Your 911 integration, critical infrastructure presence, and increasingly sophisticated technology platforms mean EMS is a critical national security partner.

The decisions EMS agencies make regarding communications equipment, data systems, and unmanned aircraft have implications beyond individual patient care. The drone transmitting video from your mass casualty incident could be simultaneously transmitting that intelligence to foreign servers. The platform you deploy for wilderness search could be used to map critical infrastructure. The system you use for training could be cataloging your operational patterns and capabilities.

Conclusion

The FCC's December 22, 2025 ruling represents a fundamental market restructuring with profound implications for EMS drone operations. While short-term disruption is unavoidable as agencies verify supply chain compliance and transition from foreign platforms, the long-term trajectory creates opportunity for those who act strategically.

EMS leaders should not view this as a compliance burden but as an opportunity to build partnerships with verified U.S. manufacturers, access federal funding streams, and position their agencies as national leaders in secure public safety drone operations. The programs that succeed will be those that recognize their shared role in national security and act accordingly.

The future of EMS drone utility will continue to develop new solutions for tactical medicine, delivery/rotation of whole blood, remote patient assessment, automated supply delivery, and applications we haven't yet imagined. Ensuring that the future is built on secure, domestically-produced platforms isn't just regulatory compliance; it is an operational and national security necessity.

About the Author

Donnie Woodyard, MAML, NRP, is a nationally recognized EMS leader, author, and policy expert with nearly three decades of experience spanning frontline emergency response, state and federal executive leadership, and system-level governance. He currently serves as Executive Director of the United States EMS Compact, the governmental body responsible for facilitating interstate practice of EMS, and is the author of multiple best-selling books on EMS leadership, history, and emerging technology, including artificial intelligence in emergency medical services. Donnie is an FAA fixed-wing airplane pilot and a commercial drone pilot, bringing practical aviation and UAS operational insight to public safety policy discussions. His work focuses on professionalism, accountability, regulatory strategy, and the responsible integration of technology into EMS systems.

The views and opinions expressed are solely my own and do not represent any current or former employer.

References

Federal Communications Commission. (2025, December 22). Public Safety and Homeland Security Bureau announces addition of foreign-produced unmanned aircraft systems and UAS critical components to the Covered List [Public notice]. https://www.fcc.gov/supplychain/coveredlist
National Defense Authorization Act for Fiscal Year 2025, Pub. L. No. 118-159, § 1709, 138 Stat. 1773, 2209-10 (2024).
Department of the Army. (2017, August 2). Discontinue use of Dajiang Innovation (DJI) Corporation unmanned aircraft systems [Memorandum].
Department of Defense. (2018, May 23). Memorandum: Suspension of procurement and operation of commercial off-the-shelf unmanned aerial systems [Memorandum].
Federal Communications Commission. (2025, December 22). Fact sheet: National security determination regarding foreign-produced UAS and UAS critical components [Fact sheet].
National People's Congress of the People's Republic of China. (2017). National Intelligence Law of the People's Republic of China.
Cyberspace Administration of China. (2021). Regulations on the management of network product security vulnerability.
Department of Homeland Security. (n.d.). National Special Security Events [Fact sheet].
The White House. (2022). National Security Strategy of the United States of America.
Congressional Research Service. (2023). Unmanned aircraft systems in the Ukraine conflict (CRS Report No. Rxxxx).
Federal Communications Commission. (2025, October 28). Order establishing process for limiting previously granted authorizations of covered equipment [Report and order].
Florida Department of Management Services. (2023). Approved unmanned aerial systems (UAS) list and restrictions for government agency use [Rule/guidance].
Defense Innovation Unit. (2023). Blue sUAS 2.0 cleared list [Program documentation].
Duke Health. (2025, November 18). Drones now deliver AEDs during real 911 calls in first-of-its-kind U.S. study [Press release]. https://corporate.dukehealth.org/news/drones-now-deliver-aeds-during-real-911-calls-first-its-kind-us-study
Tampa General Hospital. (2024, April 23). Tampa General Hospital, Manatee County, and ArcherFRS introduce first-in-the-nation program to deliver life-saving emergency response equipment via drone delivery [Press release]. https://www.tgh.org/news/tgh-press-releases/2024/april/tgh-manatee-county-archerfrs-introduce-first-drone-delivery-emergency-response-equipment
Market research forecast. (2024). Medical drone delivery services market forecast 2024-2034.