Executive summary

On 13 August 2026, the United States (US) President issued a proclamation titled Adjusting Imports of Unmanned Aircraft Systems and Unmanned Aircraft Systems Components into the United States, adjusting the imports of covered unmanned aircraft systems (UAS) and their parts and components. The proclamation imposes tiered ad valorem duties under Section 232 of the Trade Expansion Act of 1962, as amended (Section 232) on UAS and UAS components identified in the proclamation's Annex I, II and III, establishing reduced-rate treatment for specified trading partners, and creating an onshoring incentive program administered by the Secretary of Commerce (the Secretary). The relevant Harmonized Tariff Schedule of the United States (HTSUS) modifications are set out in Annex IV. The duties apply in addition to any other applicable duties, taxes, fees and charges, except as otherwise specified.

The action follows a report from the Secretary, who found that UAS and UAS components are being imported "in such quantities and under such circumstances as to threaten to impair the national security of the United States." The report cited substantial import penetration, reliance on foreign sources for critical components such as motors, electronic speed controllers, lithium-ion batteries and docking stations, information security risks and insufficient domestic production capacity.

Tariff framework

The proclamation establishes the following ad valorem rates for covered products:

• 100% on UAS with a "maximum take-off weight of more than 25 kilograms," UAS that integrate thermal imagers, UAS docking stations and certain critical UAS components listed in Annex I, effective 3 September 2026, unless a lower rate applies under the partner-cap or onshoring provisions
• 25% on UAS with a maximum takeoff weight of 25 kilograms or less listed in Annex II, effective 3 September 2026, unless a lower rate applies under the partner-cap or onshoring provisions
• 25% on certain additional UAS components listed in Annex III, effective 9 February 2027

Additionally, the Secretary is authorized to add further UAS components to the scope of the tariffs on a rolling basis, effective as set out in a notice in the Federal Register.

Partner caps and certification

The proclamation caps the applicable duty rate for products of specified trading partners, inclusive of any Column 1 HTSUS rate:

• No higher than 15% for products of Japan, the Republic of Korea, Taiwan, Switzerland, Liechtenstein or a European Union member state
• No higher than 10% for products of the United Kingdom

These caps apply only if importers certify that substantially all critical components and technology are products of the United States, Japan, the Republic of Korea, Taiwan, Switzerland, Liechtenstein, a European Union member state or the United Kingdom. The Secretary will establish a process to determine whether products meet these criteria and will inform US Customs and Border Protection (CBP) of qualifying products.

Administration and effective dates

HTSUS and effective dates

Subchapter III of Chapter 99 of the HTSUS is modified as provided in Annex IV. The Annex I and Annex II rates apply to goods entered for consumption, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on 3 September 2026, and the Annex III rate applies on or after 12:01 a.m. Eastern Time on 9 February 2027.

Onshoring incentive program

The Secretary will establish a program to encourage new investment in US facilities that produce UAS and UAS components (Covered Products). Companies may submit onshoring plans that commit to build, refurbish or expand a US facility, with construction commencing before 20 January 2029. If the Secretary approves a plan, the company may import Covered Products for its supply chain and necessary production equipment, in volumes commensurate with the facility's reasonably anticipated annual output, without paying applicable Section 232 duties during the construction period.

Approved plans are subject to monitoring, reporting and potential external audits. The Secretary may cease and rescind tariff benefits if a company substantially fails to meet its commitments, and rescission may be retroactive if the US Executive Branch assesses fraud or deliberate misrepresentation, with CBP authorized to collect additional tariffs owed.

Blue UAS and Conditional Approval list companies

For companies on the Department of Defense's Blue UAS Cleared List or Blue UAS Framework, or the Federal Communications Commission's Conditional Approval List as of 2 September 2026, the effective date for covered products and their components is delayed to 9 February 2027. The Secretary will inform CBP of the qualifying companies and products.

Duty drawback

Only manufacturing drawback is available for the duties imposed. Drawback applies only if the article (1) is not of a type subject to an antidumping or countervailing duty order (AD/CVD), (2) is a product of Trade Agreement Partners (the United Kingdom, the European Union, Switzerland, Liechtenstein, Japan, the Republic of Korea, Mexico, Canada and any partner with which the United States concludes a trade and security agreement), and (3) consists, at least 85%, of the products of Trade Agreement Partners.

Foreign trade zones

Products described in Annex I, Annex II or Annex III that are admitted into a US foreign trade zone on or after the effective date, other than products eligible for domestic status, must be admitted under privileged foreign status and will be subject upon entry for consumption to the ad valorem rates applicable to their HTSUS classification.

Key dates

• 13 August 2026: Proclamation issued
• 2 September 2026: Cutoff for Blue UAS Cleared List, Blue UAS Framework and Federal Communications Commission (FCC) Conditional Approval List status for the delayed effective date
• 3 September 2026: Effective date for Annex I (100%) and Annex II (25%) rates
• 9 February 2027: Effective date for Annex III (25%) components, and delayed effective date for qualifying Blue UAS and Conditional Approval list companies
• Within 120 days of the proclamation: The Secretary to provide the President with a status update on UAS and UAS component imports
• Before 20 January 2029: Construction commitment deadline for approved onshoring plans

What this means for businesses

Businesses importing UAS and UAS components may face significant new duty exposure, with rates ranging from 25% to 100% depending on annex placement, product weight, functionality and origin. Resulting duty treatment will depend heavily on precise HTSUS classification and annex mapping, including whether a product incorporates thermal imaging capabilities or qualifies as a docking station.

In addition, the partner caps introduce new certification requirements regarding the origin of critical components and technologies, creating enhanced documentation, supply chain traceability and compliance obligations. Although the onshoring program may provide a pathway to duty-free treatment during the construction phase, participants should be prepared for ongoing monitoring, reporting and audit requirements.

Actions to consider

Businesses affected by these changes should, depending on their particular circumstances, consider the following actions:

• Review classification of products in accordance with US classification rules.
• Identify UAS and UAS components across Annexes I, II and III to determine tariff exposure to the 100% and 25% rates and confirm HTSUS Chapter 99 treatment under Annex IV.
• Assess eligibility for the 15% and 10% partner caps, including the importer certification requirements for critical components and origin of the technology .
• Evaluate the onshoring incentive program and whether new US production commitments support duty-free treatment during facility construction.
• Model duty drawback and foreign trade zone outcomes, including the manufacturing drawback conditions and Trade Agreement Partner content requirements.
• Monitor forthcoming Federal Register notices and CBP guidance, including rolling additions of components and the Blue UAS and Conditional Approval list determinations.