The US Department of Commerce has moved to formally add China’s DJI, the leading manufacturer of drones globally, to its Entity List. The Entity List, which is already available online and will be published officially on the 22nd, documents the seventy-seven entities that are “acting contrary to the national security or foreign policy interests of the United States”.
While we have seen US government agencies take several actions to support domestic US manufacturers of drones, this action takes these efforts to a new level.
In this article, we discuss everything about this Entity List addition, and how it will impact the industry, broken out into the following four sections:
- Impacts to Availability of DJI Drone Hardware
- Why is DJI on the Entity List?
- Will DJI Be Taken Off the List?
- What is Next for the Drone Industry?
Impacts to Availability of DJI Drone Hardware
While the addition to this list will seriously hamper DJI’s regular business operations, it IS NOT a broad ban on DJI products. Instead, the list and related sanctions are made to limit “exports, reexports and transfers” to these companies, not the purchase of a listed companies’ products.
Essentially this will limit DJI’s abilities to procure US-made technology and components that its products rely on. While DJI does not disclose a list of its suppliers, we believe these areas are where US technology is being used in DJI products:
- Various DJI cloud services, such as their websites, backend app storage systems, SkyPixel, FlightHub and more (Amazon Web Services)
- Smart battery BMS, potentially all products (Texas Instruments)
- Vision chips, potentially all consumer products (Intel & Ambarella)
- Legacy thermal imaging cameras, Zenmuse XT/XT2 and Mavic 2 Enterprise Dual (FLIR)
- Mobile app availability, all DJI mobile apps (Apple’s App Store, Google’s Amazon Play Store)
It is possible for these American companies to apply to have their license to sell to DJI reviewed, but there is a presumption of denial. The presumption of denial does not exist for items necessary for fighting COVID-19.
Potential DJI customers should be particularly worried about the impact to DJI’s cloud services and smart battery management system (BMS). The BMS is critical to maximizing flight time and safe landings. If a new BMS supplier is improperly integrated, future DJI drones would be more likely to fall out of the sky due to these rules. On the cloud services side, if DJI were to quickly move to another supplier, this could have implications on how customer’s drone data is stored and potentially moved overseas.
I would speculate that DJI will not be severely impacted by these limitations to procurement, as they are likely to have been moving their supply chain to Chinese suppliers in anticipation of being added to the list. This is made clear by DJI’s introduction of its Mavic 2 Enterprise Advanced drone just before being added to the list, which moved their current generation thermal imaging drones away from FLIR sensors and to a (presumably) Chinese supplier.
These limitations will speed DJI’s efforts to dropping US suppliers and cement entirely separate global supply chains for drones. We expect that there will be a huge buyout of DJI’s existing stock in the weeks to come by US distributors, with stock of DJI products becoming an issue in the middle of 2021. For companies that want to continue to purchase DJI hardware, there is no legal ban to you doing so, but the supply of their products may be unreliable.
Why is DJI on the Entity List?
Many in the drone industry suspected cybersecurity concerns would be the death of DJI. Surprisingly, the US Commerce Department has not directly cited these concerns. While they did not speak specifically about any particular entity being added to the list, they cited two categories of activities behind all entities added to this list: (1) “enabling wide-scale human rights abuses within China” and (2) “facilitated the export of items by China that aid repressive regimes around the world”.
Enabling wide-scale human rights abuses within China
While the Chinese human rights abuse claims were not elaborated on, there has been one story that has followed DJI about the usage of its drones in China’s Xinjiang province.
In Bloomberg Businessweek’s detailed piece about DJI, they wrote about an article posted by DJI announcing a strategic cooperation with the public security bureau of Xinjiang. The online statement was removed by DJI once Bloomberg asked questions about the partnership, and no explanation was provided by DJI other than the person leading this project had left the company.
To our knowledge, there are no other reports around human rights abuses by DJI. It is possible there are US Intelligence reports about the involvement of DJI technology in China’s vast surveillance state, which could also have influenced the US Department of Commerce.
Exporting items to aid repressive regimes around the world
The United States has previously gone after Chinese firms who have sold US technology or components to Iran. While we haven’t seen claims that DJI products have similarly gone directly against US sanctions, there is a large amount of reporting around the usage of DJI products for illicit purposes by non-state or anti-American actors, including by ISIS/ISIL and an attempted assassination of Venezuela’s president.
DJI has attempted to limit the use of its products in war zones by instituting no-fly zones through software updates, but there are limitations to these restrictions.
Lastly, we come full circle to DJI’s supply chain. DJI has previously used FLIR thermal sensors, with high frame rate (30 Hz) versions of these versions being export controlled under International Traffic in Arms Regulations (ITAR), due to their potential military applications. This limits the exportation of these products to countries allied with America. When moving to non-US thermal sensors, DJI does not need to follow ITAR regulations. While this behaviour falls outside of ITARs purview, this action itself could inherently be seen as aiding America’s enemies.
All of these issues are avoidable through tight controls by DJI of their sales channels. However, it is important to note that DJI does not publish any guidelines on who it sells to or how it limits the use of its products for nefarious purposes. That is a stark contrast to Skydio, a young US manufacturer of autonomous drones, who has published their own “engagement and responsible use principles”.
DJI’s first statement about being added to the entity list did not address any of these concerns, instead assuring customers that they can continue to buy their products:
DJI is disappointed in the U.S. Department of Commerce’s decision. Customers in America can continue to buy and use DJI products normally. DJI remains committed to developing the industry’s most innovative products that define our company and benefit the world.DJI’s statement on being added to the US Entity List
The question remains around exactly what concerns warranted being added to the entity list. DJI still has many questions to answer around ways it ensures drones don’t end up in the hands of terrorists and its potential involvement in Xinjiang.
Will DJI Be Taken Off the List?
This action began under the Trump administration and could end with President-Elect Biden once he is in office. While some might speculate that Biden’s administration will move to undue this action by Trump, we do not believe this is so simple.
Biden ran on a policy focused partially on restoring the global order and America’s place in it. Banning companies from doing business with each other does not align with setting transparent rules and will decouple the Chinese and American economies, which theoretically reduces the cost of engaging in war.
Despite our speculation that Biden’s administration would be against these rules, Biden has run on a tough on China platform, and will not offer China anything for free. We see the Entity List as a free bargaining chip that he can use in negations with China, and therefore DJI is not likely to see a quick removal from the Entity List.
With his administration to deal with the COVID-19 pandemic first, it may take much of 2021 for China to become a focus for the administration, and even longer for China to play seriously. All eyes should be on the Georgia runoff, which will determine how fast Biden’s administration can move on all issues.
We suspect that DJI will continue to be in the crosshairs of US lawmakers for years to come, as DJI will play a critical role in Chinese ambitions in the transportation industry. This is not just in the drone space, where they control 69% of the global market, but will trickle over into other areas as DJI’s ambitions grow, as we have seen recently with their move into low-cost LiDAR sensors.
What is Next for the Industry?
While DJI products will not disappear from the market overnight, adding DJI to the Entity List will have impacts across the drone industry. DJI drones are consumer, commercial and civil users’ preferred choice, making up 69% share of all global drone purchases. In the short term, even as DJI products remain in supply across the market, we’ll see a chilling effect on purchases, especially in the commercial market.
While the commercial and civil drone space has seen an increasing number of non-DJI alternatives – from China’s Autel to France’s Parrot and America’s Skydio – the consumer, prosumer and photography/cinematography market lacks alternatives.
This is more clearly laid out by looking at DJI’s product lines. Its enterprise aircraft, like the Mavic 2 Enterprise and Matrice 300 Series, have many alternatives, albeit how mature and available these alternatives are remains a question.
Their consumer lines – like the Mavic and Phantom airframes – have fewer alternatives as many competitors have left this market entirely (3D Robotics, GoPro, Parrot). China’s Autel offers some alternatives, and Skydio’s consumer lines have similar specs, but its different control scheme and emphasis on autonomy is a larger jump for current DJI customers. Neither of these players have alternatives to the DJI Mini 2, a full featured drone at just $450 and below the weight limit requiring registration by the FAA.
In short, we’ll likely see the hardware sector stall over the next year as DJI competitors either scale out their supply chains to meet the demand or diversify their product line to capture more of DJI’s market share. DJI will invest in adjusting its supply chain. Consumers and businesses should expect limited availability of all drones on the market and higher prices as they move to DJI alternatives.
Learn More About the Drone Industry
- Explore the new US drone hardware ecosystem and how government policies have supported its growth.
- Learn how DJI’s drone dominance was born, the consumer market faltered and may rise again.
- See how COVID-19 has increased interest in consumer drones.
- Understand the four forces that shaped the drone industry in 2020.