Per the Associated Press, China’s Commerce Ministry on Wednesday said it would attach export controls to drones that could be converted and deployed on the battlefield, as well as certain equipment, such as infrared lasers.

At the same time, the country will lift unspecified temporary restrictions on certain consumer drones. About a year ago, China imposed export controls on both civilian and military drones that could be used for “non-peaceful purposes.”

The changes will take effect on September 1.

Western countries have been angling for greater restrictions on China, which is the world’s largest exporter of consumer drones, but sanctions and export controls have not entirely quelled concerns.

For example, DJI, the country’s largest drone manufacturer, suspended direct sales to Russia and Ukraine, but the company’s aircraft are still reaching the battlefield. In response, the U.S. has sanctioned individual Chinese companies suspected of supplying Russia with drones via third-party networks and countries, such as through Iran.

U.S. lawmakers have been particularly harsh on Chinese drone manufacturers, comparing DJI to TikTok and pushing for an array of restrictive bills.

One measure, the American Security Drone Act, was even included in the 2024 National Defense Authorization Act (NDAA), barring procurement of Chinese drones by federal agencies.

Another bill, the Countering CCP Drones Act, aims to add DJI, Autel, and other Chinese manufacturers to the Federal Communication Commission’s covered list, which would effectively end all new sales to the U.S. at both the federal and consumer levels. Some U.S senators are working to get the legislation added to next year’s NDAA.

The anti-China bills come amid FBI and Department of Homeland Security assessments that the drones could pose a cybersecurity threat, coupled with allegations that the aircraft are using their cameras to spy on Americans and transmit data back to China.

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Last week, the U.S. State, Commerce, and Treasury departments brought an array of sanctions against Russian entities and individuals, including Zala Aero, the manufacturer of the Lancet kamikaze drone that is being deployed by the Russian military against Ukraine. The sanctions target Zala and several firms in Russia and abroad thought to be supplying Moscow with uncrewed aerial vehicle (UAV) technology.

The sanctions mark the first direct action the U.S. government has taken to target the Lancet, which according to British military intelligence has helped Russia create a “step change” in its offensive capability through precise, long range, one-way attacks.

“Russia deploys Lancets to attack priority targets, and they have become increasingly prominent in the key counter-battery fight, striking enemy artillery,” the U.K. Ministry of Defense said in a recent report. “Traditionally, Russia has used small UAVs mainly for reconnaissance. With its attack capability, Lancet has been a step change in how Russia uses this category of weapons.”

So-called loitering munitions such as the Lancet are designed to be piloted over enemy territory, “loitering” in the air until a target is identified. They then swoop down and detonate. Ukrainian soldiers have described the UAVs as one of the main threats they face on front lines. The aircraft cost only around $35,000 to make, allowing Russia to deploy them in droves.

“The Lancet has been a powerful weapon for Russia, providing a high-speed precision strike capability for use against Ukrainian artillery and Western-supplied armored vehicles and tanks,” Dr. James Rogers, executive director of Cornell University’s Brooks Tech Policy Institute, told FLYING. “In many ways, the Lancet has been key to blunting Ukraine’s counter-offensive.”

The Sanctions

The State Department’s nearly 100 sanctions include “a network procuring items in support of the production of the KUB-BLA and Lancet suicide drones being used by the Russian military in Ukraine.” KUB-BLA kamikaze drones are also produced by Zala.

The restrictions target Zala—a subsidiary of Kalashnikov Group, which is thought to produce about 95 percent of Russia’s small arms and is best known for the AK-47 assault rifle—and A Level Aerospace, a manufacturer and seller under the Zala brand. They designate Zala owner Aleksandr Zakharov, along with his wife, three children, and the companies they own.

Russian firms known to be supplying Zala, as well as United Arab Emirates-based companies procuring technology for the Russian military, were also blacklisted.

The Commerce Department, meanwhile, added 13 companies—12 of them Russian—to its entity list, barring exports of American-made tech. The sanctions are “some of the Department’s most severe export restrictions” and are aimed specifically at limiting the procurement, development, and proliferation of Russian drones. Targeted firms include Zala and several others on the State Department’s list.

“It is imperative that we remain clear-eyed about our mission to degrade and diminish [Russian President Vladimir] Putin’s ability to wage war against the Ukrainian people,” said Alan Estevez, under secretary of commerce for industry and security. “Today’s additions to the entity list highlight that no U.S. technology can be used to further our adversaries’ objectives.”

The Treasury Department’s sanctions, of which there are 130, focus primarily on throwing a wrench into Russia’s international supply chain in order to disrupt sanctions evasion. 

In particular, firms in the UAE, China, and Turkey—thought to be part of a Russian weapons procurement network supplying “critical components that Russia relies on for its weapons systems”—were singled out.

“Russia is dependent on willing third-country individuals and entities to resupply its military and perpetuate its heinous war against Ukraine, and we will not hesitate in holding them accountable,” said Treasury Secretary Janet Yellen. “Today’s actions demonstrate our further resolve in continuing to disrupt every link of Russian military supply chain and target outside actors who would seek to support Russia’s war effort.”

The U.S. has cracked down on a few of these third-country procurement networks in recent months. For example, last week a Brooklyn resident and two Russian nationals were charged with conspiracy and other crimes for an export control scheme that benefitted Russian drone manufacturers.

In August, Artur Petrov, a Russian-German national, was charged with export violations, smuggling, wire fraud, and money laundering by the U.S. Attorney’s Office in the Southern District of New York for orchestrating a sanctions evasion scheme. Petrov used shell companies to acquire U.S.-made microelectronics, which have been found in Russian drones and guided missiles recovered on the battlefield in Ukraine.

At this point in the conflict, it is well known that Russia also deploys Iranian-made Shahed-136 kamikaze drones and quadcopters produced by China’s DJI, relying on suppliers in those countries to stock its barracks. While these models were not mentioned in the latest round of sanctions, the U.S. appears to be treating such networks more seriously by restricting the third-country portion of Russia’s supply chain.

The Lancet Threat

Russia has been using a common variant of the Lancet, the Lancet-3, or Product-51, for months. The kamikaze drones have been effective, but a range of about 25 miles limits their severity somewhat. However, recent videos appear to show Lancet-3s striking Ukrainian fighter jets from 45 miles away.

In reality, these were next-generation variants called the Izdeliye-53 or Product-53, which are designed to fly in swarms and communicate with one another in the air. The models are deployed from small, ground-based tubes similar to mortars, unlike Product-51, which is launched by a pneumatic rail.

“The main thing about the drones is their ease of use,” Zakharov, also chief designer for Zala, told Russian television last month. “The ease of use and almost complete autonomy from any means of counteraction. That is, it will be almost impossible to fight against them.”

According to the Institute for the Study of War (ISW), a Washington, D.C.-based think tank, Russian sources claim the country began using the Product-53 on October 21. As Zakharov alluded to, the new design reportedly has an automatic guidance system that distinguishes between different kinds of targets and boosts strike success rates.

Per the ISW, Product-53s are not being widely used. But Russian forces have been testing them for “mass synchronized swarm strikes.” The think tank also reported that Russia allegedly deployed a Product-24 or “Italmas” drone—another improved variant of the original Lancet— in a strike on Kyiv Oblast.

With a payload of only 3 to 5 kilograms (about 6 to 11 pounds), the new Lancet models may lack the ability to significantly damage Ukrainian targets, as ISW hypothesized. Still, the prospect of them flying in swarms could be troublesome.

Will Sanctions Be Effective?

The U.S. sanctions on Lancet drones were well received by Ukrainian President Volodymyr Zelenskyy, who described them as “powerful” and reiterated his confidence in Ukraine’s success.

“This is what is needed,” Zelenskyy said in a nightly video briefing on November 2. “Every sanctions decision must work in full—so that there is no chance for Russia to circumvent the sanctions. The power of sanctions is the power of the world.”

But whether the sanctions are necessary and whether they are effective are two different conversations.

In a February fact sheet, the Treasury Department touted the efficacy of its sanctions on the Russian economy and military procurement. But a December Congressional Research Service report said that while sanctions have created some friction, they haven’t quite packed the punch experts expected.

“The sanctions have created challenges for Russia but to date have not delivered the economic ‘knock out’ that many predicted,” the report reads.

Moscow itself appears to be unfazed by the new round of restrictions. Maria Zakharova, a spokeswoman for the Russian foreign ministry, told Russian state television the country has “learned how to overcome them.”

“This is a continuation of the policy of inflicting as they call it—a strategic defeat on us,” Zakharova said. “They will have to wait in vain forever before that happens.”

However, the hope is that the sanctions can move the needle and at least bother Russian frontline forces, who are “relying heavily” on Lancet drones as they struggle to be effective, according to the ISW. Shahed loitering munitions and DJI drones will likely still pose a problem. But any hindrance to Russia’s Lancet production could go a long way.

According to Rogers, the restrictions on Russia’s third-party network could have a significant impact on Moscow’s ability to produce the UAV.

“The Lancet is comprised of at least 19 technical elements that are U.S. in origin,” Rogers told FLYING. “This includes components like network controllers produced in Dallas and semiconductors for image processors produced in Wilmington, [Massachusetts]. As such, the sanctions should have a demonstratable impact on Russia’s ability to acquire U.S. technologies from third-party suppliers.”

The sanctions come as Ukraine looks to ramp up its own domestic drone production to “dozens of thousands” of UAVs per month. 

The country has frequently relied on foreign suicide drones, such as the Turkish Bayraktar TB2 or U.S.-made Switchblade loitering munitions. But it’s propped up homegrown manufacturers in recent months with initiatives such as the Army of Drones, and it’s calling on Western countries to do the same as the world contends with wars in Eastern Europe and the Middle East.

The U.S. has also sanctioned individuals and entities in Iran, China, Russia, and Turkey that are thought to have ties to Iran’s military drone procurement network. In addition to supplying Russia with Shahed drones, Iran is reportedly providing Hamas militants with technology and training.

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Several Chinese government agencies on Monday announced the imposition of new restrictions on exports of both military and civilian drones used for “non-peaceful purposes.” While the new controls did not explicitly address the Russia-Ukraine conflict, they could reduce China’s support of the Russian offensive and quell international concerns around its involvement in the war.

“China’s modest expansion of the scope of drone control this time is an important measure to demonstrate its commitment as a responsible major country to implement global security initiatives and maintain world peace,” the country’s Ministry of Commerce said in a statement.

China also expressed concern about drones that have been converted for military use, including some that are refurbished and re-exported to Russia by way of a third country.

“The risk of some high specification and high-performance civilian unmanned aerial vehicles being converted to military use is constantly increasing,” the Ministry of Commerce said.

Many exports will still be allowed. But drones with certain features will face export controls extending far beyond Russia when the restrictions take effect September 1. They are expected to be lifted after two years.

What the Controls Cover

Specifically, China will restrict exports of drones that can fly beyond the view of the operator, remain airborne for more than 30 minutes, carry more than 7 kilograms (about 15 pounds), or throw objects using attachments. These restrictions apply to military as well as consumer-grade drones.

The controls also cover certain radio equipment and hyperspectral, multispectral, and precision infrared cameras the drones may carry. Further, drone manufacturers will need government permission to export products with certain engines, lasers, imaging capabilities, communications and radio gear, and even anti-drone systems.

Exporters will need to provide the Chinese government with evidence of the drone’s end user and ultimate activities. And manufacturers will have the responsibility of assessing whether their products have the potential to be used for the “proliferation of weapons of mass destruction, terrorist activities, or military purposes.”

Notably, civilian drones not included in the new controls will not be allowed to be exported for military purposes. That means, for example, that China will not be able to ship publicly available DJI drones to Russia for surveillance purposes.

The new controls expand China’s existing export restrictions on drones, issued in 2015. The previous rule, for example, banned exports of drones that could fly as long as an hour, a restriction that will now be cut in half. According to the Ministry of Commerce, China has implemented such restrictions for roughly two decades.

The ministry also noted that some companies have independently halted operations in Russia and Ukraine. DJI, for instance, pulled out of both countries in April 2022. In a statement, DJI said it has never designed or marketed equipment for military use and added it would “actively cooperate” with the restrictions.

The Chinese government has repeatedly declared its neutrality in the ongoing conflict, though Beijing continues to remain friendly with Moscow. Shortly before Russia’s invasion of Ukraine, the countries announced a “no-limits partnership,” and China has blocked efforts to censure Moscow in United Nations proceedings, among other shows of support.

DJI has also been accused by a German retailer of leaking data on Ukrainian military positions to Russia, a claim it rejected as “utterly false.”

President Joe Biden has warned Chinese President Xi Jinping of unspecified consequences for supporting the Russian war effort. But that has not appeared to drive a wedge between the two.

Last week, a U.S. intelligence report citing Russian customs data and other publicly available data said that Chinese equipment is increasingly fueling the Russian offensive. Data showed that China state-owned military contractors supplied $12 million in drones and drone parts to Russia as of March. China refuted the report and has previously criticized claims of its support for Russia as “deliberate smears.”

However, Russian use of Chinese drones—including DJI products—during the war has been well-documented. The Ukrainian side has reportedly used them as well.

The Role of U.S.-China Tensions

It’s possible China’s new drone export restrictions are an attempt to smooth things over with the U.S. amid rising tensions.

The U.S. last year sanctioned Chinese drone companies, preventing them from buying advanced chips and chip-making equipment without a license. China fired back last month, placing controls on two materials crucial to the production of semiconductors.

But the U.S. has been particularly aggressive in restricting Chinese drones.

China is the world’s leading supplier of the technology, and DJI reportedly owns more than half of the American drone market share. The company’s products are particularly popular among U.S. public safety agencies. Some estimates place DJI’s share of the market for U.S. public safety drones as high as 90 percent.

However, concerns that the drones are spying on American citizens and critical infrastructure have materialized in a series of sweeping bans at the federal and state levels.

In 2018, the Department of Defense banned the purchase of all commercial off-the-shelf drones. The following year, it restricted the purchase and use of drones and components made specifically in China, and it added the company to a formal DOD blacklist last fall.

Both the Commerce and Treasury departments have also limited the use of Chinese drones. The former added DJI and other manufacturers to its entity list in 2020, barring U.S. companies from selling them components. The latter, meanwhile, placed DJI and others on its investment blacklist in 2021. Both measures came in response to alleged human rights abuses involving the use of drones to surveil Uyghur Muslims in China.

In addition, Florida, Arkansas, Mississippi, and Tennessee have all introduced bans on the use of Chinese drones by public agencies, including law enforcement. And in April, House Republicans introduced a bill called the Countering CCP Drones Act that would effectively ban all consumer, enterprise, and military sales of DJI products.

The new restrictions in China could further hamper DJI and other Chinese manufacturers. To comply with the new controls, some companies may need to modify or fully remove certain features, such as high-powered sensors and cameras.

Although the restrictions are designed to reduce the possibility of DJI products finding their way onto the battlefield, U.S. law enforcement agencies have mixed feelings. Many worry about the impact of removing the drones from their fleets without immediate replacements, while others claim the cost and performance of Chinese models are far superior to approved alternatives.

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