NDAA BlueUAS Compliant Series

Last updated 15 September 2023

Read our latest blog post on how we achieve NDAA and EO13981 compliance at BotBlox.

BotBlox's commitment to compliance with NDAA and EO13981 

As the current geopolitical situation continues to evolve, we at BotBlox are watching closely and can see certain trends developing. We supply a number of large NATO entities (both large and small), and while we must avoid taking a political opinion, we must ensure we meet the requirements of our customers in terms of our supply chain. Of specific relevance to our industry is the NDAA (National Defense Authorization Act) and Executive Order 13981. 

NDAA Compliance relates to the prohibition on telecommunications and video surveillance equipment from a list of specific companies in the People's Republic of China (PRC). BotBlox is an a OEM, however we do use manufacturers in the PRC for some of our boards.

Executive Order 13981 is more general, and specifically prohibits the use of components from adversary countries to be contained in UAS systems used for in missions of strategic or sensitive nature. These adversary countries are listed below. Of these countries, the only one with of consideration with respect to Electronics and UAS is China.

  • The Democratic People’s Republic of Korea
  • The Islamic Republic of Iran
  • The People’s Republic of China
  • The Russian Federation

BotBlox supplies telecommunications equipment that is heavily used in drones, so Executive Order 13981 is of huge consequence to our business, and thus we are taking action to ensure compliance.

Stage 1 

The first stage of this action will be the reduction of our reliance on Chinese manufacturers, which we will achieve by releasing a parallel line of our Standard Series boards that are manufactured outside the PRC. These will be labelled as our NDAA/EO13981 Compliant Series, and manufacture will take place in the EU or USA, and components sourced outside of the four adversary countries listed above. We will supply full traceability statements under NDA to show customers the locations of our supply chains.

It should be noted that initially, these NDAA/EO13981 Compliant Boards will come with a slightly higher price tag and MoQs. It should also be noted that our Rugged boards are already manufactured outside of the PRC, however they do use some passive components originating from the PRC.

Stage 2

As we reduce our reliance on China, we aim to migrate all of our series of boards towards NDAA/EO13981 compliance, at which point our mainline offerings will be compliant by default. We should be able to achieve this compliance without hugely impacting the prices we offer to our customers. It is at this stage that we will branch off our Chinese made boards as a "Low Cost Series", to provide a lower cost option to customers who are not sensitive to compliance.

Conclusion

The truth is that the Chinese electronics ecosystem is highly optimised and thus does offer competitive prices, however it is essential that our supply chain is diversified enough so that it can withstand potential trade restrictions with China, and also satisfy our customers who must ensure NDAA/EO13981 compliance.

Update as of 18 November 2023

At time of writing we are well into Stage 1 of this process. A parallel supply chain has been setup with our manufacturer in Thailand and an IC component supply chain based in the UK/EU. The following boards are now available as COTS hardware with no MoQ.

The following boards are available currently made to order and have MoQs, but we expect to have them available as COTS with no MoQ in the next few months.

Any of our products are available on request as an NDAA compliant version. Please contact us at info+ndaa@botblox.org if you have a specific board you would like as an NDAA form factor.

For easy of differentiation. all NDAA compliant boards are Blue, compared to our Red (standard series) boards and Green (rugged series) boards.

Updates to the NDAA legislation

Recent updates to the NDAA rules (outlined in Fiscal Year 2023 NDAA Sec 817) change the meaning of NDAA compliance significantly. Where previously, NDAA compliance only applied to specific companies with the PRC, it now applies much more broadly to covered countries (Iran, China, North Korea and Russia). 

Thankfully the rules here are essentially identical to those found in Executive Order 13981, which our NDAA series boards are already compliant with. Read more about this in our blog post here.

Is BotBlox a part of the BlueUAS program?

The BlueUAS program is for suppliers of full drones rather than components. However our NDAA boards are used by certified companies of the BlueUAS program. Read more about that here.