Introduction

In February 2024, RMC’s White Paper “Small Unmanned Aerial Systems (sUAS) and the Force Protection Threat to DoD” outlined the potential uses, characteristics, and capabilities of sUAS. As highlighted in the paper, the Department of Defense (DoD) acknowledges that an adversary employing sUAS could challenge American military advantage and degrade the Joint Force’s freedom of maneuver across multiple domains. At the same time, civilians and private organizations use drones for filmmaking, law enforcement, utility inspections, emergency response, agriculture, and delivery. According to the Federal Aviation Administration (FAA), forecasts highlight the possibilities for as many as 1.92 million small recreational UAS units by 2028.^[1],[2],[3]

Over the past decade, Chinese drone companies, especially Da Jiang Innovations (DJI), have dominated the global commercial UAS market. While Shenzhen-based DJI controls a majority of the sUAS market share throughout the U.S. and the world, the “DoD’s Statement on DJI Systems” explicitly indicates that DJI poses “potential threats to national security.” The following white paper will outline DJI’s popularity in the drone market, examples of state and non-state actors employing DJI sUAS, potential security concerns associated with the company, and restrictions and legislation addressing Chinese-manufactured drones.^[4]

DJI’s Founding and Evolution

In 2006, Frank Wang founded DJI as a student at the Hong Kong University of Science and Technology to develop a flying toy that would not crash most of the time. While DJI released its first quadcopters in 2011, its introduction of the first Phantom drone in 2013 revolutionized the market by providing an inexpensive model with straightforward controls. In 2016, DJI offered new imaging and flight capabilities in the Mavic Pro. The drone’s efficient design enabled consumers to transport the units easily and proved essential for future improvements to DJI’s designs and functionality. Furthermore, in 2018, the Mavic Air’s release introduced a lightweight model with new preprogrammed flight modes, autonomous operation, and unique features. Following these aerial innovations, DJI debuted its flagship Mavic 2 Pro and Zoom to provide high-end camera options, safety features, and simple operating and flying mechanisms. DJI Mavic 3’s release in 2022 included significant capability improvements, including approximately 45 minutes of flight time, omnidirectional obstacle sensing, and a transmission range of 15 km. The cost-to-flight ratio between the DJI Phantom and DJI Mavic 3 models, released almost 10 years apart, increased by 17.5%.^{[5],[6],[7],[8],[9]}

Figure 1 illustrates the DJI Mavic 3 Pro’s estimated transmission range within the setting of Washington, D.C.

Figure 1
DJI Mavic 3 Pro: Transmission Ranges to and from the Washington Monument

These developments and further innovations helped DJI capture approximately 77% of the American hobby drone market and 90% of the global commercial drone service provider market, according to estimates from 2020. More recent estimates concur that DJI continues to control most of the market. DJI drones also have been widely used by American public-safety agencies. According to open-source reports released in 2023, DJI drones comprised a majority of sUAS units registered by local governments and police departments in New Jersey and systems used for official operation in the State of New York. Furthermore, before a recent ban was initiated in Florida, almost half of the drones registered by state and local governments and police departments there were manufactured by DJI. In addition, security forces and government agencies of allies of the U.S. rely on DJI systems. For example, as of 2023, DJI products comprise more than two-thirds of drones operated by police forces in the United Kingdom.^[9],[10]

Employment of DJI Drones

DJI drones used in the Russian-Ukraine conflict highlight the platform’s capabilities. Small recreational UAS models like the DJI Mavic quadcopter have assisted both armies in reconnaissance missions and delivering bombs. For example, in March 2023, Ukraine obtained 300 DJI Mavic 3T UAVs through its “Army of Drones” program. According to a Ukrainian press release, each aerial vehicle included a thermal sensor and a high-powered zoom camera that allows an operator to conduct reconnaissance, artillery, and night operations. An unclassified report from the Office of the Director of National Intelligence also revealed that China had shipped more than $12 million in drones and components to Russia as of March 2023. While DJI announced in 2022 that it would suspend all sales in Ukraine and Russia, a study of at least 1,000 cases of drones used for reconnaissance and attacks in the conflict from March 2022 to March 2023 found that DJI platforms accounted for more than half of identifiable units.^{[11],[12],[13],[14],[15],[16],[17]}

Open-source reporting also reveals the use of DJI drones in the Israel-Hamas conflict. Expert analysis of the 07 October 2023 attack indicates that Hamas employed modified commercial quadcopter drones, including aerial vehicles manufactured by DJI, to drop explosives onto Israel’s observation towers. These attacks successfully disrupted sensors, communications, and weapons systems along the border of Gaza. Footage from one of the attacks shows an armed DJI quadcopter drone taking out an Israeli Merkava tank. The IDF has also used DJI platforms for their operations, including the DJI Avata, to explore tunnels constructed by Hamas.^{[18],[19],[20],[21],[22]}

Finally, analysis from the assassination attempt of former President Trump in Butler, PA, on 13 July 2024 indicates that the gunman surveyed the area using a DJI drone. Roughly two (2) hours before the rally, the 20-year-old gunman flew the drone about 200 yards from the stage for approximately 11 minutes. Investigators also found the drone in the shooter’s car after the attempt on the former president’s life.^[23],[24]

Security Concerns and Bans on DJI Drones

In 2015, China initiated its “Made in China 2025” strategic plan, which is a ten-year effort to invest in key industries and maintain its global leadership and market dominance. China has promoted sophisticated market mechanisms and minimized red tape to initiate rapid growth as part of this effort. Furthermore, the PRC’s “Military-Civil Fusion” and “The National Security Law of the PRC” indicate that citizens and private organizations in China are required to assist the government and intelligence services with security issues. The Chinese Community Party remains committed to these strategies and laws within the commercial drone industry, directing companies to invest significantly in drones and components, develop domestic supply chains, and acquire and transfer western technology. For example, open-source reports reveal that at least four (4) Chinese investment companies with close ties to the PRC are investors in DJI. These investors include the China Chengtong Holdings Group, Shanghai Venture Capital Guidance Fund, Guangdong Hengjian Investment Holding, and the State Development & Investment Corporation. With the PRC’s strong backing of its drone industry over the past decade, DJI and other Chinese companies have been able to flood the worldwide market with lower-cost drones that have more advanced capabilities.^{[25],[8],[26]}

Figure 2 illustrates China’s extensive global UAS exports in 2023.

Figure 2
Chinese UAS Exports and Imports, 2023^[27]

Given the PRC’s expanded control of companies and data within China, the Cybersecurity and Infrastructure Security Agency (CISA) and the Federal Bureau of Investigation (FBI) released a “Cybersecurity Guidance” document in January 2024 addressing Chinese-manufactured UAS. According to CISA and the FBI, “the use of Chinese-manufactured UAS in critical infrastructure operations risks exposing sensitive information to PRC authorities, jeopardizing U.S. national security, economic security, and public health and safety.” The document highlights that the many points of connections associated with UAS can present exploitation opportunities. For example, updates managed by Chinese entities can lead to unknown data collection and transmission capabilities without the owner’s knowledge.^[28]

On 24 May 2017, the Department of the Navy released an internal memo citing the operational risks of using the “DJI Family of Products.” According to the memo (released under the Freedom of Information Act), DJI systems have potential cyber vulnerabilities, particularly involving the data link between the aircraft and the ground station. On 02 August 2017, the U.S. Army issued a memo ordering all personnel to stop using DJI drones due to cyber vulnerabilities. In June 2019, Congress passed the National Defense Authorization Act (NDAA) for FY2020, which prohibits the operation or procurement of UAS manufactured in a “covered foreign country” (defined as China by Public Law 116-92) by the DoD for military activities and the Department of Energy for defense activities. In addition, the Department of Commerce added DJI to its Entity List on 21 December 2020, terminating DJI’s access to American technology, suppliers, and markets.^{[29],[30],[31]}

In January 2021, Executive Order 13981 and the passing of Senate Bill 73 prohibited the federal government from procuring or using UAS models manufactured or assembled by entities based in China or subject to influence or control by the PRC. Two (2) years later, the U.S. Senate passed a similar bill, the American Secure Drone Act of 2023, which was incorporated into the NDAA for FY2024. A few states also have banned DJI products, including Florida and Mississippi. Mississippi’s Senate Bill 2853, passed in 2023, requires all sUAS units acquired by the state or any agency or political subdivision to be purchased from a manufacturing company incorporated and headquartered in the U.S.^{[32],[33],[34]}

Countering Chinese Communist Party (CCP) Drones Act Overview

In February 2022, Congresswoman Elise Stefanik (R-NY) introduced the “Countering CCP Drones Act,” which passed the House of Representatives on 09 September 2024. The bill requires telecommunications and video surveillance equipment or services produced by DJI to be included on a “list of communications equipment or services determined by the Federal Communications Commission (FCC) to pose an unacceptable risk to U.S. national security.” Other companies on the “Covered List” include Huawei Technologies Company, ZTE Corporation, and Hangzhou Hikvision Digital Technology Company. Proponents of the bill cite national security concerns and indicate that banning DJI drones from operating on American communications infrastructure will foster the growth of a competitive domestic drone industry. The Countering CCP Drones Act now sits with the Senate, with some predicting the Senate version of the 2025 National Defense Authorization Act (NDAA) could incorporate the bill.^{[35],[36],[37]}

While the Countering CCP Drones Act has earned bipartisan support, many companies and industry representatives oppose the bill. Critics claim banning DJI drones could limit commercial options and increase costs for companies and consumers. They also assert that a ban on DJI drones could disrupt the operations of law enforcement agencies, first responders, and farmers who rely on the company’s products. DJI states that lawmakers therein “reference inaccurate and unsubstantiated allegations regarding DJI’s operations” and denies that their drones “collect flight logs, photos, or video by default.” DJI continues to fight against market restrictions by sponsoring and maintaining the Drone Advocacy Alliance website.^[35],[38]

Ongoing Developments

In 2022, the DoD included DJI on its list of “Chinese military companies” (CMC) operating directly or indirectly in the U.S. in accordance with the statutory requirement of Section 1260H of the NDAA for FY2021. On 18 October 2024, a former U.S. Attorney General filed a lawsuit against the DoD on behalf of DJI for including the company. In the lawsuit, DJI argues that it is “neither owned nor controlled by the Chinese military.” DJI claims that it has “lost business deals, been stigmatized as a national security threat, and been banned from contracting with multiple federal government agencies” due to the DoD’s decision. This lawsuit shortly follows open-source media reports that DJI informed distributors that the U.S. Customs and Border Protection is citing the Uyghur Forced Labor Prevention Act (UFLPA) to withhold some sUAS units from being imported. The UFLPA prohibits importation of goods produced entirely or partly in the Xinjiang region in response to what the U.S. government details as forced labor abuses directed at Uyghurs and other Muslim minority groups.^[39],[40]

Conclusion

In the “Cybersecurity Guidance” referenced above, CISA and the FBI encourage public and private sector organizations to reference the DoD’s Blue UAS Cleared List for models compliant with federal cybersecurity policies. After the FY2020 NDAA was signed into law, in which section 848 prohibited specific components from covered countries, the Defense Innovation Unit (DIU) started the Blue UAS initiative in August 2020. Blue UAS maintains and includes a list of policy-approved commercial UAS models for DoD and government users that are validated by the DIU as “cyber-secure” and “safe to fly.”  As of May 2024, the Blue UAS Cleared List includes at least 26 platforms manufactured by 14 different entities. A platform added to the list requires a DoD customer to sponsor its inclusion or has the capability to meet a DoD customer’s needs when the DIU initiates a “Commercial Solutions Opening.” As DJI and other Chinese drone companies encounter increasing market restrictions within the U.S., public and private entities could consult the DIU’s evolving Blue UAS Cleared List to meet their commercial drone needs.^[41]

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[14] Ross. P.E. (2023, May 17). Budget Drones in Ukraine Are Redefining Warfare. Spectrum. Retrieved from https://spectrum.ieee.org/drone-warfare-ukraine.

[15] Luzin, P. (2023, November 23).  Russian Military Drones: Past, Present, and Future of the UAV Industry. FPRI. Retrieved from https://www.fpri.org/article/2023/11/russian-military-drones-past-present-and-future-of-the-uav-industry/

[16] Crumley, B. (2024, March 31). Ukraine sends 300 DJI Mavic 3T drones to battle Russians ahead of expected offensive. Drone DJ. Retrieved from https://dronedj.com/2023/03/31/ukraine-sends-300-dji-mavic-3t-drones-to-battle-russians-ahead-of-expected-offensive/.

[17] Vallance, C. (2022, April 27). Chinese drone firm DJI pauses operations in Russia and Ukraine. BBC. Retrieved from https://www.bbc.com/news/technology-61179022.

[18] Kaniewski, D. (2023, October 20). Hamas: Learning about drone warfare from the war in Ukraine. DW. Retrieved from https://www.dw.com/en/hamas-learning-about-drone-warfare-from-the-war-in-ukraine/a-67169578.

[19] Byman, D., McCabe, R., Palmer, A., Doxsee C., Holtz, M., and Duff, D. (2023, December 19). Hamas’s October 7 Attack: Visualizing the Data. CSIS. Retrieved from https://www.csis.org/ analysis/hamass-october-7-attack-visualizing-data.

[20] Armitage, R. (2023, November 05). The skies over Gaza are abuzz with drones. Some are Israeli, some are American, and some are flying bombs made by Hamas. ABC. Retrieved from https://www.abc.net.au/news/2023-11-06/drones-flying-over-and-within-gaza/103067280.

[21] Jankowicz, M. (2023, October 10). How Hamas likely used rudimentary drones to ‘blind and deafen’ Israel’s border and pave the way for its onslaught. Business Insider. Retrieved from https://www.businessinsider.com/hamas-drones-take-out-comms-towers-ambush-israel-2023-10.

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[23] Kosnar, M., & Dilanian, K. (2024, July 19). Trump shooter flew drone over venue hours before attempted assassination, source says. NBC News. Retrieved from https://www.nbcnews.com/news/us-news/trump-shooter-flew-drone-venue-hours-attempted-assassination-source-sa-rcna162817.

[24] Lybrand, H., Rabinowitz, H., and Cole, D. (2024, July 24). Takeaways from FBI testimony: Trump shooter searched details of JFK assassination and flew drone near rally site. CNN. Retrieved from https://www.cnn.com/2024/07/24/politics/fbi-wray-house-hearing-trump-shooting/index.html.

[25] PRC State Council. (2022, March 08). Notice of the State Council on the Publication of “Made in China 2025.” Center for Security and Emerging Technology. Retrieved from https://cset.georgetown.edu/wp-content/uploads/t0432_made_in_china_2025_EN.pdf.

[26] Cadell, C. (2022, February 1). Drone Company DJI Obscured Ties to Chinese State Funding, Documents Show. The Washington Post. Retrieved from https://www.defense.gov/News/Releases/Release/Article/2706082/department-statement-on-dji-systems/.

[27] UN Comtrade Database. (n.d). Trade Data. Retrieved from https://comtradeplus.un.org/ TradeFlow.

[28] CISA and FBI. (2024, January). Cybersecurity Guidance: Chinese-Manufactured UAS. Retrieved from https://www.cisa.gov/sites/default/files/2024-01/Cybersecurity%20Guidance%20Chinese-Manufactured%20UAS.pdf.

[29] National Security Archive. (n.d.). Department of the Navy Memorandum raised possibility of cyber vulnerabilities, susceptibility to electromagnetic interference. National Security Archive. Retrieved from https://nsarchive.gwu.edu/news/cyber-vault/2019-12-16/military-concerns-over-chinese-dji-drones.

[30] U.S. Congress. (2019, December 20). National Defense Authorization Act for FY2020. Retrieved from https://www.congress.gov/bill/116th-congress/senate-bill/.

[31] National Archives. (2020). Addition of Entities to the Entity List, Revision of Entry on the Entity List, and Removal of Entities From the Entity List. Retrieved from https://www.federalregister.gov/ documents/2020/12/22/2020-28031/addition-of-entities-to-the-entity-list-revision-of-entry-on-the-entity-list-and-removal-of-entities.

[32] U.S. Congress. (2021). S.73 – American Security Drone Act of 2021. Retrieved from https://www.congress.gov/bill/117th-congress/senate-bill/73/text.

[33] National Archives. (2021). S.73 – American Security Drone Act of 2021. Retrieved from https://www.federalregister.gov/documents/2021/01/22/2021-01646/protecting-the-united-states-from-certain-unmanned-aircraft-systems.

[34] Mississippi Legislature. (2023). Mississippi Senate Bill 2853. Retrieved from https://billstatus.ls.state.ms.us/documents/2023/html/SB/2800-2899/SB2853IN.htm

[35] Govtrack.us. (n.d.). H.R. 2864: Countering CCP Drones Act. Retrieved from https://www.govtrack.us/congress/bills/118/hr2864/text.

[36] Federal Communications Commission. (2024, September). List of Equipment and Services Covered By Section 2 of The Secure Networks Act. Retrieved from https://www.fcc.gov/ supplychain/coveredlist.

[37] Howe, S. (2024, September 24). Who’s Opposed to the Proposed DJI Ban? Commercial UAV News. Retrieved from https://www.commercialuavnews.com/who-s-opposed-to-the-proposed-dji-ban.

[38] DJI ViewPoints Team. (2024, March 1). The Countering CCP Drones Act (An Attempt To Ban DJI). Retrieved from https://viewpoints.dji.com/blog/get-the-facts-countering-ccp-drones-act.

[39] Shepardson, D. (2024, October 21). Drone Maker DJI Sues Pentagon Over Chinese Military Listing. Reuters. Retrieved from https://www.reuters.com/legal/chinese-dronemaker-dji-sues-pentagon-over-chinese-military-listing-2024-10-19/

[40] Martina, M., and Shepardson, D. (2024, October 16). US Customs halts some drone imports from Chinese manufacturer DJI, company says. Reuters. Retrieved from https://www.reuters.com/world/us/us-customs-halting-some-drone-imports-chinese-manufacturer-dji-company-says-2024-10-16/.

[41] Defense Innovation Unit. (2024, May). About Blue UAS. Retrieved from https://www.diu.mil/blue-uas.