From the definition of COTS parts in section 1 of the game manual:
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For the purposes of the FRC, generally available software modules obtained from open sources (e.g. professional publications, commonly used FRC community-accessible web resources, industry source code repositories, etc.) that are not specifically affiliated with individual FRC teams shall be considered COTS items.
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The Blue Box in <R22> clarifies this further in the last example:
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... After completing the software, they post it in a generally accessible public forum and make the code available to all teams. Because they have made their software generally available (per the Blue Box in the definition of COTS, it is considered COTS software and they can use it on their ROBOT.
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That would seem to add a significant incentive to open source your code: enabling re-use between seasons.