Six regimes.
Six different questions.
They are run by different agencies, they bite at different moments in an object’s life, and they carry different consequences. A supplier can appear on one and none of the others. A single “banned” label is the fastest way to get a supply-chain review wrong.
What reaches what
A coded matrix, not a table. Reach is pre-printed law: fixed, readable from the statutes, independent of your evidence. It is sparse on purpose. Most regimes are silent on most categories, and that pattern is the point.
Inventory category × regime reach · verified 2026-10-12
| Category | FCC auth. |
UFLPA import |
§889 procure |
1260H DoD award |
BIS export |
NS-CMIC invest |
|---|---|---|---|---|---|---|
| Cameras & capture | · | p | · | p | · | · |
| Wireless video, comms & radios | G | p | G | p | · | p |
| Drones & aerial | G | p | · | G | p | p |
| On-set networking | G | p | G | G | p | · |
| Site security & venue CCTV | G | p | G | p | p | G |
| LED volumes & projection | · | G | · | p | · | · |
| Batteries, solar & location power | G | G | · | G | p | p |
| Workstations, storage & cloud | · | p | p | p | G | · |
| Wardrobe, costume & soft goods | · | G | · | · | · | · |
| Catering & craft services | · | G | · | · | · | · |
| AI models & services | · | · | · | G | G | p |
| Robotics & production vehicles | G | p | · | G | p | p |
They attach to the company, not to the object. The first four columns are ordered by the moment a regime bites something you own: FCC at equipment authorization, UFLPA at import, §889 at procurement, 1260H at DoD contract award. BIS restricts what you may export to an entity; OFAC NS-CMIC restricts trading its securities. Neither attaches to a camera in your truck. Reading them on the same axis is the most common and costly mistake here.
Two rows are worth reading against each other. Wardrobe and catering are nearly empty except under UFLPA, which is why a producer who has only ever screened cameras has a gap. On-set networking is dense across four regimes at once.
§889: covered telecom and surveillance
Reaches: GpGp·p wireless · networking · venue CCTV
Five covered entities plus subsidiaries and affiliates: Huawei and ZTE for all telecommunications equipment, and Hytera, Hikvision and Dahua for video-surveillance and telecommunications equipment used for public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes.
Part A (August 2019) bars federal agencies from procuring the equipment. Part B (August 2020) goes further: agencies may not contract with a company that uses covered equipment anywhere in its systems, including on private work unrelated to the federal contract. Implemented through FAR 52.204-24 and 52.204-25.
If your client, or your client’s client, is a US federal contractor, Part B makes your on-set comms and the venue’s CCTV their problem.
Sources: FAR 52.204-25 · EAC overview · DoD DPC
1260H: Chinese military companies
Reaches: pGGG·p networking · power · AI · robotics · drones
A statutory annual list, required by §1260H of the FY2021 NDAA, of companies the Department of Defense assesses as “Chinese military companies operating in the United States.” The June 2026 update lists 188 entities (80 parent companies) and removes 10. Listed names include Alibaba, Baidu, BYD, CATL, DJI, Huawei, NIO, SenseTime, Tencent, TP-Link, Unitree and WuXi AppTec.
Consequences phase in. From 2026-06-30, DoD may not enter into, renew or extend contracts with listed companies or entities they control. From 2027-06-30, DoD may not buy their products or services indirectly through third parties. Components supplied as part of an end item are exempt, and DoD can grant waivers to firms that submit a phase-out plan (§805(c)). FY2024 NDAA §805(a)(3)(C), Pub. L. 118-31.
Designations get challenged. DJI, listed since January 2024, challenged its inclusion. The district court ruled for DoD on September 26, 2025. On August 14, 2026 the D.C. Circuit affirmed in part, reversed in part and remanded so the district court can review the classified record. A listing is DoD’s assessment, not an adjudicated finding. That’s why this site records it as a flag with a source and a date, never as a verdict.
Sources: DoD list, June 2026 (PDF) · DoD release, June 8, 2026 · FR 2026-11571, June 10, 2026 · WilmerHale · Federal Register · FY2024 NDAA §805(a)(3)(C), Pub. L. 118-31 · District court, September 26, 2025 · D.C. Circuit, August 14, 2026. Counts are from the Federal Register notice (FR 2026-11571, June 10, 2026).
FCC Covered List: equipment authorization
Reaches: GGGG·· wireless · drones · networking · CCTV · power · robotics
Maintained under the Secure and Trusted Communications Networks Act, the Covered List determines which equipment may receive FCC authorization for the US market. It includes the five §889 names, and on December 22, 2025 the FCC added foreign-produced UAS and UAS critical components (with DoW/DHS exemptions), blocking new authorizations. Previously authorized models may still be imported, sold and used. On June 26, 2026 it prohibited continued import and marketing of previously authorized Huawei, ZTE, Hytera, Hikvision and Dahua equipment (DA 26-635, effective July 16, 2026. Hytera/Hikvision/Dahua only for the listed security uses. Existing equipment can still be used.)
On July 28, 2026 the list extended again, to foreign-produced advanced robotic devices, including humanoid and quadruped systems, and to connected power inverters used in renewable, battery, grid and data-center infrastructure. The action blocks authorization of new covered models rather than prohibiting devices already in use, and it applies by foreign production rather than naming China alone. Certain routers were added on March 23, 2026 (FCC Covered List).
Drone fleets, wireless video and any RF-emitting kit bound for a US shoot. It now also covers mobile robots used for camera movement, stunts or demonstrations, plus connected inverters on location power. A drone legal to fly in Hong Kong may be un-authorizable for a US production. Record the exact model and its authorization status, production origin, remote-control capability, and an operational substitute.
Sources: FCC Covered List · FCC notice DA 26-786, July 28, 2026 · Federal Register
UFLPA: the forced-labor import presumption
Reaches: GGGp·· wardrobe · catering · power · LED · and most upstream metal
Enacted in December 2021 and enforced since June 21, 2022, the Uyghur Forced Labor Prevention Act applies to goods made wholly or in part in Xinjiang, or by entities on the DHS-maintained Entity List. Goods are presumed made with forced labor and barred from US entry. To rebut, the importer must fully comply with CBP guidance, answer CBP’s questions completely, and show by clear and convincing evidence that the goods were not made with forced labor; CBP then has to grant an exception.
The list grows in waves, and not steadily: 26 textile firms in May 2024; 37 in January 2025, including Zijin Mining and Huafu Fashion with 25 subsidiaries; then, after more than eighteen months, the largest single addition yet (the previous largest was 30 in Nov 2024). The list is 187 entities by our count of the DHS UFLPA Entity List (last updated July 31, 2026), including 45 effective August 3, 2026, about 32% growth. Many listed entities operate outside Xinjiang; the trigger is the supply-chain link, not the address.
Priority sectors reach further than most productions expect
The statute names cotton, tomatoes, and polysilicon. Aluminum, PVC, and seafood were added in the July 2023 strategy update. Caustic soda, copper, jujubes, lithium, and steel came in later updates (latest 2025-08-19).
Read against a call sheet:
- Cotton and apparel: wardrobe, costume, crew apparel, set textiles, soft cases.
- Tomatoes: catering and craft services, including paste and prepared foods, alongside Xinjiang wine and dried fruit common in HK and TW food-service chains.
- Polysilicon: solar and location power.
- Aluminum, copper, steel: grip and rigging, camera accessories, LED panel frames and drivers, cabling.
- Lithium and battery materials: camera, light and drone batteries; mobile power.
The point for a production is narrower: the label a stylist reads in Hong Kong may not carry the origin information the same garment carries elsewhere. Off-the-shelf wardrobe can introduce listed-region cotton without any procurement decision being made.
Sources: DHS UFLPA Entity List · DHS FAQs · DHS announcement, July 31, 2026 · UFLPA · DHS UFLPA strategy · DHS strategy update, August 19, 2025 · CBP UFLPA. 187 entities by our count of the DHS UFLPA Entity List (last updated July 31, 2026), including 45 effective August 3, 2026.
BIS and NS-CMIC: company, not object
The BIS Entity List restricts exports, reexports and in-country transfers of items subject to the EAR (including some foreign-made items) to listed parties. It constrains what you may supply to them, not what you may buy from them. For a production its relevance is as a corporate-risk signal, and as a real constraint if your workflow would transfer controlled US technology to a listed party. That’s why it governs the workstations, storage and cloud row, and the AI row. BIS’s 50% affiliates rule (90 FR 47201) is suspended until November 9, 2026 (90 FR 50857). Whether it will be extended again is uncertain.
The OFAC NS-CMIC List is maintained under EO 13959 as amended by EO 14032. From 60 days after listing, US persons may not buy or sell its publicly traded securities. Purchases or sales made solely to effect divestiture are allowed until 365 days after listing. Its criteria include operation in the surveillance-technology sector. Unlike the SDN list, there is no 50% rule. A subsidiary is restricted only if OFAC names it. It is an investment measure: it does not prohibit owning or using a listed company’s camera, but it is a material input to a client’s overall trust posture and to a US-listed client’s own disclosure thinking.
Sources: Bureau of Industry and Security · 15 CFR 744.11 · 90 FR 47201 · 90 FR 50857 · OFAC CMIC program · OFAC FAQ 899 · OFAC FAQ 857 · CNAS analysis
Every screening flag in a generated review names which list, the match basis (statutory name, parent, subsidiary, or name similarity) and the list version date. Name matching is fallible and corporate structures change. These are US regimes, not global bans; for clients in government, finance, or international brands, listed-entity exposure is a material trust finding regardless of jurisdiction.