August 6, 2026

FCC Covered List Expands to include Foreign-Produced Advanced Robotic Devices

Effective July 28, 2026, the Federal Communications Commission’s (FCC) Covered List now includes foreign-produced power inverters and foreign-produced advanced robotic devices. These equipment categories are now prohibited from receiving new FCC equipment authorizations.

The term “foreign-produced” refers to any article that does not qualify as a “domestic end product,” as that term is defined in 48 CFR § 25.101(a). This article is focused on guidance pertaining to assessing whether an advanced robotic device is considered covered.

At a surface level, a mobile robot may appear to fall within the Covered List category for Foreign-produced advanced robotic devices. However, the equipment authorization status and the device characteristics should be reviewed carefully before reaching that conclusion.

Very importantly, if the manufacturer obtained FCC grants before July 28, 2026, those specific models are already cleared. If FCC authorizations such as grants of authorization or Suppliers Dealation of Conformity were not obtained before that date, the manufacturer should assess whether the device meets all conditions in Table 1 and is not excluded by any of the exclusions listed in Table 2 below.

The assessment should be made in two steps:

• First, determine whether the robot satisfies all elements of the advanced robotic device definition in Table 1.

• Second, confirm that the device is not excluded by one of the specific carve-outs. If any exclusion applies, the device should not be treated as being on the Covered List under this category.

Table 1. Conditions for an advanced robotic device

If all the conditions below are met, continue to the exclusion analysis.

Item	Condition	Met?
A	A foreign-produced mechanical mobile device, including autonomous mobile robots, humanoid robots, and quadrupeds	✓
(i)	Is capable of locomotion, obstacle avoidance, navigation, or movement on the ground.	✓
(ii)	Operates at a distance from a human operator or supervisor based on commands or in response to sensor data, or any combination of these.	✓
(iii)	The combined weight of the device and, if applicable, ground station or docking station is over 4.4 lbs.	✓
(iv)	Contains each of the required component categories listed below:	✓
1	A sensor capable of perceiving its environment.	✓
2	A component capable of providing network connectivity, wired or wireless, including Bluetooth/Wi-Fi, cellular, or satellite, with connection speeds of at least 200 kbps in either direction.	✓
3	Software running either locally or remotely, including firmware and AI or machine-learning model weights, that controls the robot’s autonomous navigation or movement perception, data collection, or remote command-and-control.	✓

Table 2. Exclusions: if any answer is “Yes,” the device is not on the Covered List

No.	Exclusion
2	A “connected vehicle,” as that term is defined in 15 CFR § 791.301, including a connected vehicle of any gross weight.
3	A vehicle operated only on a rail line.
4	An “uncrewed aircraft” or “uncrewed aircraft system,” as defined in 47 CFR § 88.5.
5	An unmanned underwater vehicle that is able to operate without a human occupant.
6	Items classified as devices under section 513 of the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. § 360c, including surgical instruments, medical and surgical robotic systems, external limb prostheses and their components, and ambulatory and mobility assistive devices such as canes, crutches, walkers, and wheelchairs, whether or not powered, and whether the item was cleared under section 510(k), approved under section 515, classified under section 513(f)(2), or exempt from premarket notification.
7	A fixed, stationary, non-mobile robot, including articulating, parallel/delta, Cartesian/gantry, or Selective Compliance Assembly Robot Arm/Articulated Robot Arm (SCARA) robots intended for industrial or medical use.

Helpful definitions

Connected vehicle: A vehicle driven or drawn by mechanical power and manufactured primarily for use on public streets, roads, and highways, that integrates onboard networked hardware with automotive software systems to communicate via dedicated short-range communication, cellular telecommunications connectivity, satellite communication, or other wireless spectrum connectivity with any other network or device.

Uncrewed Aircraft (UA): An aircraft operated without the possibility of direct human intervention from within or on the aircraft.

Uncrewed Aircraft System (UAS): A UA and its associated elements, including an uncrewed aircraft station, communication links, and components not on board the UA that control the UA, that are required for safe and efficient operation in the airspace of the United States.

If the device meets all the conditions in Table 1 and none of the exclusions apply, then effective July 28, 2026, the advanced robotic device is on the Covered List. Existing products already properly authorized before July 28, 2026, remain valid though there are rules on updates to products (see notes below).

Notes and timing considerations

Conditional Approval Deadline (January 1, 2028): Foreign manufacturers seeking a waiver to continue receiving FCC equipment authorizations must submit a machine-readable PDF application for Conditional Approval to conditional-approvals@fcc.gov no later than this date.
Software Update Waiver Expiration (January 1, 2029): A temporary blanket waiver issued by the FCC Office of Engineering and Technology (OET) allows operators to deploy routine software and firmware updates to previously FCC-authorized hardware. This safety window expires at the start of 2029.
Logic-bearing component changes: If a manufacturer changes a logic-bearing physical component on an existing, grandfathered robot model, the device loses its grandfathered status. It is then treated as a new model and requires a fresh equipment authorization, which will be blocked unless it has secured conditional approval.

References

FACT SHEET: FCC Updates Covered List to Include Foreign-Produced Advanced Robotic Devices and Power Inverters

National Security Determination on the Threat Posed by Foreign-Produced Advanced

Tags: Wireless and Telecom , Radio, wireless and telecom , FCC

Vina Kerai

Vina is located in Nemko’s US office and she is responsible for Nemko’s Telecommunications Certification Body programs. Vina has a proven track record of successfully implementing and managing certification programs with over 18 years of experience from R&D/engineering, compliance testing and certification to...