US Federal Communications Commission prohibits new foreign-made power inverters and mobile robots

On July 28, 2026, the US Federal Communications Commission (FCC) added foreign made connected power inverters and advanced robotic devices (certain mobile robots) to the FCC Covered List,¹ prohibiting new device models from qualifying for FCC equipment authorizations.² Devices covered by these listings will be effectively prohibited from importation, marketing, or sale in the United States, unless the manufacturer obtains a waiver. These particular listings are forward-looking and do not prohibit existing device models previously authorized by the FCC. That said, the FCC has been expanding and refining the authorities under the Covered List while it has been deploying these new product-level listing actions, and new potential restrictions affecting components, replacement parts, software updates, and previously licensed device models may emerge.

The FCC Covered List

Most radio-frequency emitting devices must be approved by the FCC before they can be imported, marketed, and sold in the United States. To address security concerns with certain telecommunications suppliers, Congress established the Covered List through Section 2 of the Secure Networks Act of 2019³, requiring the FCC's Public Safety and Homeland Security Bureau to maintain a list of communications equipment and services⁴  that pose an unacceptable risk to the national security of the United States or the security and safety of United States persons. In effect, a listing excludes the covered products from the US market.

Communications equipment and services on the Covered List are prohibited from receiving FCC radiofrequency authorizations, and specific entities on the Covered List are also prohibited from accessing Universal Service funding for listed equipment or services. Other providers of telecommunications services must also report to the FCC any purchase, rental, or lease of any covered communications equipment or service. Since the law's introduction, the FCC has expanded the application of the Covered List designations through other regulatory actions. Listed entities are now also prohibited from operating as test labs and from participating in the new US Cyber Trust Mark labeling program, while listed equipment and services are prohibited from use in submarine cables.

The FCC does not make the listing decisions itself. Instead, the FCC acts based on national security determinations made by any "Executive Branch interagency body with appropriate national security expertise," the Department of Commerce under the Information and Communications Technology and Services (ICTS) Rule, an act of Congress, or "an appropriate national security agency."⁵

The national security determinations for power inverters and advanced robotic devices

For the advanced robotic devices and power inverters Covered List actions, the FCC acted in response to national security determinations from "an Executive Branch interagency body with appropriate national security expertise."⁶ The body relayed the two determinations to the FCC on July 27, 2026, finding that:

• Power inverters produced in a foreign country (regardless of the nationality of the producer) pose the following unacceptable risks to the United States: (i) "facilitating a supply chain vulnerability that could disrupt U.S. economic security, including sectors critical to national security"; and (ii) "creat[ing] a cybersecurity risk that threatens the security of critical infrastructure and the safety of U.S. persons."
• Advanced robotic devices produced in foreign countries (regardless of the nationality of the producer) presented the following unacceptable risks: (i) "posing a supply chain vulnerability that could disrupt U.S. economic and national security"; and (ii) "creating a cybersecurity risk that threatens the security of critical infrastructure and thus the safety and security of U.S. persons."

Products covered by the two listings

The FCC Covered List actions apply to:

• Foreign-produced power inverters, except power inverters which have been granted a Conditional Approval by the Department of Defense or Department of Homeland Security.
• Foreign-produced advanced robotic devices, except advanced robotic devices which have been granted a Conditional Approval by the Department of Defense.

The FCC’s listings adopt the definitions of "foreign-produced," "power inverters," and "advanced robotic devices" from the national security determinations.

Because the listings are based on product and place of production, entities that produce covered devices in foreign countries are not "identified on the Covered List" and will not be subject to any entity-specific restrictions.

Definition of covered "power inverters"

For the purpose of [the power inverters] determination, the term "power inverter" shall mean a device [that is]: 

1. A bi-directional power device or system that converts direct current electricity to alternating current electricity, or converts alternating current electricity to direct current electricity, to include microinverters, string inverters, central inverters, and hybrid (battery-based) inverters; and 
2. Contains components that enable remote communication, control, sensing, data collection, or monitoring through Wi-Fi, cellular, Bluetooth, or other similar connections.

Definition of covered "advanced robotic devices"

For the purpose of [the advanced robotics devices] determination, the term "advanced robotic devices" means: 

1. A mechanical mobile device, including autonomous mobile robots, humanoid robots, and quadrupeds, that – 
   • Is capable of locomotion, obstacle avoidance, navigation, or movement on the ground; 
   • Operates at a distance from a human operator or supervisor based on commands or in response to sensor data or any combination thereof; and 
   • The combined weight of the device and, if applicable, ground station or docking station is over 4.4 lbs; and 
   • Contains a component falling within each of the below subparagraphs:
     • a sensor capable of perceiving its environment; 
     • a component that is capable of providing network connectivity (wired or wireless, including Bluetooth/WiFi, cellular, or satellite) with connection speeds of at least 200 kbps in either direction; and
     • 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; and
2. Does not include: 
   • A "connected vehicle," as that term is defined in 15 CFR § 791.301, but including a connected vehicle of any gross weight;
   • A vehicle operated only on a rail line; 
   • An "uncrewed aircraft" or "uncrewed aircraft system," as defined in 47 CFR § 788.5; 
   • An unmanned underwater vehicle that is able to operate without a human occupant; 
   • Items that are 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; and
   • A fixed, stationary, non-mobile robot, including articulating, parallel/delta, Cartesian/gantry, or Selective Compliance Assembly, or Articulated, Robot Arm (SCARA) robots intended for industrial or medical use.

Scope of the listings based on "foreign-produced" status

A central concept governing the scope of the two listings is the term “"oreign-produced," which means the listings apply to covered products produced outside the United States by any company, including US companies. Conversely, products produced in the United States – even by foreign companies – are not restricted.

To define "foreign-produced," the two national security determinations rely on the Buy American statute (48 C.F.R. § 25.101(a)), under which a "foreign-produced" product is one "that does not qualify as a 'domestic end product.'" The Buy American statute restricts government purchases of supplies that are not US end-products, subject to various exceptions. To meet the definition of "domestic end product" referenced in the FCC Covered List actions, a product must:

• Be manufactured in the United States; and 
• Except for an end product that consists wholly or predominantly of iron or steel or a combination of both, the cost of domestic components must exceed 65% of the cost of all the components in the product for items delivered in calendar years 2024 through 2028 and then exceed 75% of the cost of all the components for items delivered starting in calendar year 2029; or
• For an end product that consists wholly or predominantly of iron or steel or a combination of both, the cost of foreign iron and steel must constitute less than 5% of the cost of all the components used in the end product.

Applicants seeking new equipment authorizations will need to certify that the device is not "foreign-produced."

The restrictions are waived for basic software and firmware updates

The FCC is allowing foreign-produced advanced robotic devices and power inverters to continue receiving basic software and firmware updates. In a separate waiver issued on July 28, 2026, the FCC lifted prohibitions on certain Class I and Class II Permissive Changes by waiving the applicability of 47 C.F.R. §§ 2.932(b) and 2.1043(b).⁷ These provisions, adopted in December 2025, would ordinarily exclude Covered List equipment from the certification procedures used for permissive changes to authorized equipment, which would include routine updates for models of advanced robotic devices and power inverters authorized before July 28, 2026.

As a result of the waiver, advanced robotic devices and power inverters authorized for use in the United States may continue to receive software and firmware updates necessary to ensure the continued functionality of the devices, such as those that patch vulnerabilities and facilitate compatibility with different operating systems, at least until January 1, 2029.

Opportunity for conditional exceptions and accompanying domestic content requirements

The FCC has established a process under which producers of power inverters and advanced robotic devices subject to the Covered List actions may apply for Conditional Approvals exempting them from the restrictions imposed by the listings.⁸ Under this process, which operates in the same manner for both categories of products, the Department of Defense or the Department of Homeland Security will "assess national security risks, supply chain resilience, and the applicant's commitment to establishing trusted manufacturing capacity in the United States" to determine whether the power inverter producer poses "unacceptable risks."

Any entity involved in producing a covered device can apply for Conditional Approval. The application includes information on:

• Corporate structure: Jurisdiction of incorporation and principal place of business, ownership structure, beneficial ownership, board members and their nationalities, and any arrangements that allow foreign persons or governments to influence operations.
• Manufacturing supply chain: A bill of materials, country of origin for all components and the design, entities responsible for the intellectual property and software, justification for why the product is not already manufactured in the United States, locations of manufacturing and testing, country of origin for software and firmware, assessment of supply chain concentration, identification of points of failure in the supply chain.
• A manufacturing onshoring plan: A detailed, timebound plan to establish or expand manufacturing in the United States of the product for which the manufacturer is seeking Conditional Approval, including points of contact who will provide quarterly updates on the status of the onshoring plan, descriptions of existing US manufacturing operations, committed and planned capital expenditures over the next 1-5 years, and – if applying for an extension of a Conditional Approval or a Conditional Approval for another device – an inventory of progress made so far on the onshoring plan.

The government may request additional information during review, and filing an application does not guarantee approval.

Potential for expansion and modification of Covered List actions

Potential extension of prohibitions to previously authorized devices

The FCC has historically not revoked equipment authorizations issued prior to a Covered List designation. However, on October 28, 2025, the FCC issued a final rule establishing a new procedure under which the FCC may limit previously granted authorizations for covered equipment, specifically by prohibiting the continued importation and marketing of such equipment, while still not prohibiting the continued use of devices already sold and in service.⁹

To impose limitations on existing authorizations under this new framework, the FCC would issue a separate public notice specifying the applicable limits and identifying the affected products. The FCC has not triggered this retroactive procedure for the power inverter or advanced robotic device listings. In its announcement, the FCC specifically clarifies that "being added to the Covered List today does not prohibit the import, sale, or use of any existing device models the FCC previously authorized" and that "the Covered List does not restrict the continued use by consumers of previously-purchased devices."

The FCC could revisit this position. Recent actions indicate an increased willingness to impose retroactive importation and marketing prohibitions on already authorized covered equipment. On June 26, 2026, the FCC barred the importation and marketing prohibition of certain covered equipment that had been added to the Covered List in 2024 or earlier, despite having existing authorizations.¹⁰ On July 30 and 31, 2026, the FCC also published two requests for public comments on proposal to prohibit the continued importation and marketing of certain previously authorized foreign-produced unmanned aircraft systems and critical components that were added to the Covered List in December 2025.¹¹

The growing trend of FCC Covered List actions targeting entire sectors

Initial Covered List actions focused on specific companies and their identified products. The first designations, in March 2021, covered video surveillance and/or telecommunications equipment produced by Huawei, ZTE, Hytera, and Hikvision. Most recently, on July 23, 2024, the FCC added "cybersecurity and anti-virus software produced or provided by Kaspersky Lab, Inc. or any of its successors and assignees, including equipment with integrated Kaspersky Lab, Inc. (or any of its successors and assignees) cybersecurity or anti-virus software." As late as October 2025, the FCC emphasized that Covered List equipment and services "are closely tied to the foreign adversaries, like China[.]"¹²

Since late 2025, the FCC’s approach has shifted toward broader, sector-based listings, and on December 22, 2025, the FCC added (i) all "uncrewed aircraft systems (UAS) and UAS critical components produced in a foreign country" and (ii) products from the Chinese UAS manufacturers DJI and Autel Robotics to the Covered List.¹³ The UAS listing marked the first time the FCC designated an entire sector based on place of production rather than only naming specific companies. The FCC followed with a March 23, 2026 listing covering consumer-grade internet routers produced in foreign countries.¹⁴ Consistent with the router and UAS actions, the recent advanced robotic device and power inverter listings include temporary waivers that are partially conditioned on meeting domestic production requirements.

Recent and proposed revisions and expansions of the Covered List process

The FCC Covered List framework has continued to evolve over the past year, with the agency establishing new authorities, new rules that implicate Covered List determinations, and new administrative procedures. Earlier in July 2026, the FCC adopted several significant new final rules and proposed rules to modify the Covered List, including by: (i) expanding Covered List designations to capture devices that incorporate a Covered List entity’s “logic-bearing hardware components”; (ii) requiring e-commerce platforms to display FCC IDs when marketing and selling devices; and (iii) proposing a new rule for public comment with significant changes to the equipment authorization and Covered List processes, including separating the Covered List into entries based on producers/providers and entries based on production locations, expanding supply chain disclosures, modifying rules for software and hardware updates, and expanding oversight of the Supplier’s Declaration of Conformity process, among other changes.¹⁵

_{1 The full FCC Covered List and related materials are available at the webpage "List of Equipment and Services Covered By Section 2 of The Secure Networks Act."
2 "FCC's Public Safety and Homeland Security Bureau Announces Addition of Foreign Produced Power Inverters and Advanced Robotic Devices to FCC Covered List," July 28, 2026. 
3 Section 2 of the Secure Networks Act at 47 U.S.C. §§ 1601-1609, accessible here; and in the FCC regulations at 47 C.F.R. § 1.50000-1.50006. 
4 "Communications equipment or service" means any equipment or service used in fixed and mobile networks that provides advanced communication service, provided the equipment or service includes or uses electronic components. "Advanced communications service" means high-speed, switched, broadband telecommunications capability that enables users to originate and receive high-quality voice, data, graphics, and video telecommunications using any technology with connection speeds of at least 200 kbps in either direction.
5 The Department of Homeland Security, the Department of Defense, the Office of the Director of National Intelligence, the National Security Agency, and the Federal Bureau of Investigation.
6 "National Security Determination on the Threat Posed by Foreign-Produced Power Inverters," July 27, 2026; and "National Security Determination on the Threat Posed by Foreign-Produced Advanced Robotic Devices," July 27, 2026. 
7 "Office of Engineering and Technology Announces Waiver of Prohibitions on Certain Class I And Class II Permissive Changes to Covered Foreign-Produced Advanced Robotic Devices and Covered Foreign-Produced Power Inverters," July 28, 2026.
8 "Guidance on Submissions for Conditional Approval for Foreign-Produced Power Inverters Subject to the FCC’s Covered List," July 27, 2026; and "Guidance on Submissions for Conditional Approval for Foreign-Produced Advanced Robotic Devices Subject to the FCC’s Covered List," July 27, 2026. 
9 "Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program," 90 FR 53227 (November 25, 2025).
10 “Public Safety and Homeland Security Bureau and Office of Engineering and Technology Prohibit the Importation and Marketing of Previously Authorized Covered Communications Equipment Added to the Covered List in 2024 or Earlier,” June 26, 2026. 
11 "Seeking Comment on Prohibiting the Importation and Marketing of Certain Covered UAS and UAS Critical Components and Equipment Listed in Section 1709 of FY2025 NDAA," 91 FR 48108 (July 30, 2026); "Prohibiting the Importation and Marketing of Certain Foreign-Produced Military-Grade Uncrewed Aircraft Systems (UAS) and UAS Critical Components for Non-U.S. Government, Including Those with Swarming Capabilities," unpublished FRN in FN 11 to 91 FR 48870 (August 3, 2026).
12 "Reminder: Communications Equipment and Services on the Covered List Pose an Unacceptable Risk to National Security," FCC, October 14, 2025. 
13 Public Notice: "Public Safety and Homeland Security Bureau Announces Addition of Uncrewed Aircraft Systems (UAS) and UAS Critical Components Produced Abroad, and Equipment and Services Listed in Section 1709 of the FY2025 NDAA, to FCC Covered List," December 22, 2025; and "FCC Updates Covered List to Add Certain UAS and UAS Components," December 22, 2025.
14 Public Notice: "FCC's Public Safety and Homeland Security Bureau Announces Addition of Routers Produced in Foreign Countries to FCC Covered List," March 23, 2026; and "FCC Updates Covered List to Include Foreign-Made Consumer Routers," March 23, 2026.
15 "FCC Adopts Rules to Strengthen Rules Governing Dangerous Gear," July 22, 2026; and "Third Report and Order and Third Further Notice of Proposed Rulemaking," July 23, 2026.} 

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