U.S. FCC Expands the Covered List to Include Foreign-Produced Advanced Robotic Devices

06 Aug 2026

What Manufacturers Need to Know

The U.S. Federal Communications Commission’s (FCC) decision to add certain advanced robotic devices to its Covered List represents one of the most significant U.S. regulatory developments affecting mobile robotics in recent years. The action introduces new restrictions on foreign-produced robotic platforms seeking market access in the United States and may significantly impact future product certification strategies, supply chains, and manufacturing decisions.

On July 28, 2026, the FCC published a public notice to add foreign-produced advanced robotics to the FCC’s covered list (FCC’s Covered List) (Link to Public Notice). The “covered list” goes back to 2020 with the enactment of the Secure and Trusted Communications Network Act of 2019 and is a list of products that are restricted from receiving new FCC authorizations to be imported, marketed, or sold within the United States. For products that already have FCC equipment authorization the existing models can continue to be imported, marketed and sold.

Instead, it operates by restricting FCC equipment authorization for new covered products. Because many robotic products require FCC authorization to be marketed or imported into the United States, the practical effect can be to significantly limit U.S. market access.

It is important to note that the covered list is not a direct import ban since the products can still enter the U.S. Instead, the covered list operates by restricting FCC equipment authorizations for new covered products. Robotic products that incorporate wireless transmitters, such as Wi-Fi, Bluetooth, or cellular radios, generally require FCC equipment authorization prior to being imported, marketed or sold in the U.S. The practical effect of this will be to significantly limit the U.S. market access.

The Covered List addition applies to foreign-produced advanced robotic devices that meet the FCC's definition, rather than all robotic products.

FCC 20-99 (link) clarifies that for items to be added to the list they must meet several criteria:

• The product or service must “post [] an unacceptable risk to the national security of the United States or the security and safety of United States persons[.]”
• The product or services must be “capable of” at least one of the following:
  1. routing or redirecting user data traffic or permitting visibility into any user data or packets that such equipment or service transmits or otherwise handles;
  2. causing the network of a provider of advanced communications service to be disrupted remotely; or
  3. otherwise posing an unacceptable risk to the national security of the United States or the security and safety of United States persons.”

Following a national security determination by an Executive Branch interagency body, the FCC concluded that certain foreign-produced advanced robotic devices (ARDs) pose an unacceptable risk to U.S. national security and therefore added them to the Covered List.

What are Advanced Robotic Devices?

ARDs are defined within national security determination for foreign-produced ARDs (link) which is also included as Annex C of the FCCs public notice. In general, an ARD is a mobile robotic platform that:

• Can autonomously move or navigate
• Includes environmental sensors
• Has network connectivity
• Contains software that controls sensing, navigation, or remote operation
• Exceeds the specified weight threshold of 4.4 lbs

Notably for those in the medical and industrial fields there were two important exclusions:

• Medical devices such as surgical instruments, medical and surgical robotic systems, and ambulatory or mobility assistive devices, and
• Fixed, stationary, non-mobile robots for industrial or medical use.

For the industrial automation sector, this means that traditional industrial robot arms, including many collaborative robots (cobots), will generally fall outside the ARD definition because they are fixed, stationary systems. However, autonomous mobile robots (AMRs), mobile inspection robots, and similar mobile platforms used in manufacturing and warehousing may fall within the scope of the new requirements. As robotics technologies continue to evolve, some products may not fit neatly within established categories. In these cases, manufacturers must carefully assess and document why a product does or does not meet the FCC's ARD definition.

What does this mean?

For ARDs that are foreign produced (i.e. not “domestic end products” as defined in 48 CFR §25.101(a)), the FCC will not provide new equipment authorizations, which means products cannot be imported, sold or marketed to the United States. This requirement isn’t retroactive and doesn’t restrict models already approved or products already in use.

For foreign manufacturers of ARDs who want to get the FCC authorization for their products, they now must submit an application to the Department of War (DoW) to get a conditional waiver.

As part of this application to the DoW there will be multiple disclosures required about their corporate structure, manufacturing pipelines, and global supply chains. The FCC published guidance on how to get these approvals here.

As part of the application for the conditional waiver, the applicants will need to have a time-sensitive plan to establish or expand their U.S.-based manufacturing. It is also important to note that these conditional approvals will typically have a time limitation of up to 18 months.

Existing FCC authorizations will remain valid, however foreign-produced ARDs face significant restrictions regarding future modifications or changes to the products. To address cybersecurity concerns, the FCC’s Office of Engineering and Technology (OET) simultaneously issued a waiver permitting certain software and firmware updated intended to mitigate security risks (link). This waiver is currently valid until at least January 1, 2029.

Existing FCC authorizations remain valid. However, products added to the Covered List are subject to significant restrictions regarding future permissive changes and modifications. To address cybersecurity concerns, the FCC's Office of Engineering and Technology (OET) simultaneously issued a waiver permitting certain software and firmware updates intended to mitigate security risks.

Conclusion

For foreign-based manufacturers of ARDs, it is important to first determine if your products meet the ARD definition and if those products are considered “foreign-produced”. If that is the case then companies will need to strategically evaluate if they can apply for conditional approval from the DoW which will also require a significant review of their supply chain and manufacturing strategies.

For those manufacturers who already have FCC authorizations for their foreign-produced ARDs, they will also need to review the guidelines on what changes are permitted to their model updates.

While the immediate impact on traditional industrial robots appears limited due to the exclusion of fixed, stationary robotic systems, the requirements could significantly affect manufacturers of autonomous mobile robots and other connected mobile robotic platforms. As a result, ARD classification, FCC authorization strategy, and supply-chain planning may become increasingly important considerations for companies seeking long-term access to the U.S. market.