FCC Covered List action on advanced robotic devices (2026)

The FCC Covered List action on advanced robotic devices was a July 28, 2026 update by the Federal Communications Commission's Public Safety and Homeland Security Bureau that added foreign-produced advanced robotic devices to the agency's Covered List. The entry followed a national-security determination issued by a White House-convened interagency body one day earlier. It applies to a defined class of connected mobile ground robots unless the Department of Defense, called the Department of War in the FCC documents, grants a Conditional Approval.^[1][2]

The action is often described as a foreign-robot ban, but its legal mechanism is narrower and more specific. A new covered model cannot receive the FCC equipment authorization that most electronic devices need before importation, marketing, or sale in the United States. The July 28 action did not prohibit possession or continued operation, recall products, automatically revoke previous authorizations, or stop retailers from importing and selling relevant models that the FCC had already authorized.^[1][3] It therefore sits at the intersection of AI regulation, communications-equipment law, supply-chain policy, and robotics.

Legal basis and chronology

The Covered List was created under the Secure and Trusted Communications Networks Act of 2019. The statute requires the FCC to list communications equipment or services that meet its functional criteria and have been found to pose an unacceptable national-security or safety risk by one of several specified sources. One permissible source is an executive-branch interagency body with appropriate national-security expertise. The FCC must monitor those determinations and change the list when their status changes.^[4]

On July 27, 2026, a White House-convened interagency body determined that all foreign-produced advanced robotic devices, as it defined that category, posed unacceptable supply-chain and cybersecurity risks. Its determination allowed an exception when the Department of War transmitted a specific finding that a particular device or class did not pose those risks.^[2] On July 28, the FCC bureau accepted the definitions and added this entry to the list:

Foreign-produced advanced robotic devices, except advanced robotic devices which have been granted a Conditional Approval by DoW.^[1]

The appended Covered List dated inclusion to July 28, making the restriction operative that day. The entry is based on place of production, not on a list of manufacturers. The FCC consequently said that separate rules and programs triggered when an entity itself is identified on the Covered List did not attach merely because a company produced a robot within this category.^[1]

The equipment-authorization consequence comes from the Secure Equipment Act of 2021 and the FCC rules implementing it. The Act directed the Commission to stop reviewing or approving authorization applications for Covered List equipment.^[5] Section 2.903 of the FCC rules applies the prohibition to equipment that otherwise would use certification, a Supplier's Declaration of Conformity, or an exemption from authorization.^[6] An applicant must certify under section 2.911 that its equipment is not prohibited, and must submit a new certification if the Covered List changes before the authorization is granted.^[7]

The FCC documents use Department of War and DoW for the agency that evaluates robotics exceptions. Executive Order 14347 authorized that name as a secondary title for the Department of Defense in nonstatutory executive-branch documents, while expressly leaving statutory references controlling.^[13] Federal law continued to establish the Department of Defense under that name at the research cutoff.^[14]

Covered-device test

The determination does not regulate every device that might informally be called a robot. An advanced robotic device must be a mechanical mobile device and meet every part of a cumulative test. The examples in the definition include an autonomous mobile robot, a humanoid robot, and a quadruped, but the product label alone does not decide coverage.^[2]

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The weight prong includes the dock or ground station when one applies. The connectivity threshold is satisfied in either upload or download direction. Software can run locally or remotely, so moving a control service into the cloud does not by itself place a device outside the definition. Every listed component category is required, however. A device that lacks one of them does not satisfy the complete test.^[2]

The functional language reaches farther than humanoids and robot dogs. Depending on a model's design, it can encompass connected household cleaning machines, robot lawn mowers, sidewalk delivery robots, warehouse vehicles, and mobile inspection platforms. Industry guidance has accordingly advised companies to evaluate products by function and production location, rather than assume that consumer or industrial branding settles the question.^[15][17] It is still inaccurate to say that every robot vacuum or warehouse robot is automatically covered: the individual product must meet the remote-operation, weight, sensor, connectivity, software, and ground-mobility requirements.

Express exclusions

The determination removes six groups from the definition:^[2]

1. A connected vehicle as defined in 15 CFR 791.301, including a connected vehicle of any gross weight.
2. A vehicle that operates only on a rail line.
3. An uncrewed aircraft or uncrewed aircraft system as defined in 47 CFR 88.5.
4. An unmanned underwater vehicle that can operate without a human occupant.
5. Items classified as devices under section 513 of the Federal Food, Drug, and Cosmetic Act. The text names surgical instruments, medical and surgical robotic systems, external-limb prostheses and their components, and powered or unpowered mobility aids such as canes, crutches, walkers, and wheelchairs. The exclusion does not depend on one particular FDA premarket route.
6. Fixed, stationary, nonmobile robots intended for industrial or medical use, including articulating, parallel or delta, Cartesian or gantry, and selective-compliance assembly or articulated robot-arm designs, commonly called SCARA robots.^[2]

The fixed-robot exclusion does not create a general exemption for anything used in a factory. A mobile warehouse or inspection platform can remain within the definition even when its purpose is industrial. Conversely, a stationary industrial arm is expressly outside the category even if it has sensors, network access, and sophisticated control software.^[2][17]

Meaning of foreign-produced

The determination defines foreign-produced by reference to the federal procurement rule for a domestic end product in 48 CFR 25.101(a). For an ordinary manufactured product that is not predominantly iron or steel, that rule uses two requirements: manufacture in the United States and domestic component cost exceeding 65 percent for items delivered from 2024 through 2028. The component threshold rises to 75 percent beginning in 2029. The regulation waives the component-cost test for commercial off-the-shelf items, except for its separate iron-and-steel rule, but United States manufacture remains part of the test.^[8]

This incorporated standard makes manufacturer nationality an unreliable shortcut. A product of a United States-headquartered company can be covered if it is made abroad or otherwise fails the domestic-end-product test. A company headquartered abroad can produce a qualifying domestic product in the United States. Country of assembly, component sourcing, the commercial off-the-shelf exception, and product-specific facts can all matter.^[8][15]

The entry lists the completed advanced robotic device, not every actuator, battery, sensor, or chip as a separate covered category. Components nevertheless affect the domestic-content analysis and may need to be disclosed in a Conditional Approval application. The test should therefore be applied to a particular model and its production record rather than inferred from a brand's home country.^[9]

Equipment-authorization effects

For a new model that meets the device and production tests, section 2.903 blocks FCC equipment authorization unless a Conditional Approval removes the Covered List barrier. Because most electronic devices require equipment authorization before lawful importation, marketing, or sale, the practical result is to keep an unauthorized new covered model out of those channels.^[3][6] A product is not grandfathered merely because it was designed, manufactured, ordered, or placed in inventory before July 28. It must already have received the relevant FCC authorization.^[15]

The FCC's contemporaneous fact sheet drew a clear line around what the July 28 action did not change:^[3]

• Consumers may continue using devices they previously acquired.
• Retailers may continue importing, marketing, and selling relevant models that were already authorized.
• The action does not recall equipment or revoke an earlier authorization.
• Purchase or use by the federal government and federal agencies is unaffected.^[3]

This distinction matters when using the word ban. The Covered List entry is not itself a general customs order forbidding every foreign robot, nor is it a rule against owning or operating one. It is a prospective authorization restriction that usually has import and sales consequences for new covered models. It also applies to production in any foreign country, not just China.^[1][3]

Previously authorized equipment is not necessarily insulated from every future FCC action. Rules effective in December 2025 created a separate procedure for limiting an earlier authorization and stopping continued importation or marketing of selected covered equipment.^[11] The Commission used that procedure in June 2026 for some categories added in 2024 or earlier, while expressly excluding equipment added in 2025 or 2026.^[12] The July 28 robotics notice did not invoke that procedure, so a future possibility should not be confused with the effect of this action.

Software and firmware waiver

The December 2025 rules also restricted permissive changes to equipment that later became covered. Without relief, those provisions could have prevented even some security patches for robots authorized before July 28. The Office of Engineering and Technology therefore issued a waiver on the same day as the listing.^[10][11]

Through at least January 1, 2029, covered robots authorized before July 28 may receive Class I and Class II software or firmware changes that mitigate harm to consumers. The waiver names vulnerability patches, changes needed for continued functionality, and operating-system compatibility as examples. It does not grant a general right to redesign hardware or bypass the rest of the equipment-authorization rules.^[10]

For a Class II change, the grantee must still provide complete information and test results, meet applicable performance requirements, wait for acknowledgement before marketing the modified equipment, and make the required covered-equipment certification. The waiver suspends only the specific Class I and Class II prohibitions for qualifying software and firmware changes.^[10]

Conditional Approval

Conditional Approval is a national-security exception, not an FCC equipment authorization. A producer must first persuade the Department of Defense that a specified foreign-produced device or class does not present the risks identified in the determination. If the Department sends a favorable specific determination, the FCC bureau updates the Covered List. The producer must then satisfy the ordinary technical and procedural requirements for equipment authorization.^[1][9]

Only the Department of Defense may evaluate the robotics applications. The Department of Homeland Security can evaluate submissions for the separate power-inverter category, but the robotics entry gives DHS no corresponding role. Applications must be filed by January 1, 2028 as machine-readable PDFs and include an officer's certification that the submission is true, complete, and accurate.^[9][15]

The guidance organizes the requested information into three broad areas:

Corporate structure and control. Applicants must identify legal organization, principal locations, parents, subsidiaries, affiliates, and joint ventures. Required ownership information includes beneficial owners with interests of at least 5 percent, board and executive leadership nationality and residence, and foreign-government ownership, control, influence, financing, or support.^[9]

Manufacturing and supply chain. The submission calls for a detailed bill of materials; countries of origin for components, designs, onboard software, and firmware; entities that own relevant intellectual property or control updates; manufacturing, final-assembly, and testing sites; country concentration by value and volume; sole-source dependencies; contingency plans; and an explanation of why the product is not made in the United States and what alternatives exist.^[9][16]

United States onshoring plan. The applicant must provide a time-bound manufacturing plan, a responsible contact and office, current domestic facilities and employment, and projected investment over one to five years. The guidance asks applicants to quantify expected hiring, added manufacturing floor space, capital commitments, and progress under any prior approval. The filed plan becomes the benchmark for quarterly progress reports to the issuing agency.^[9][15]

Submitting the requested information does not guarantee approval. The Department may seek more information, and the guidance makes its decisions final while allowing modification at the Department's discretion. A willful violation or material misrepresentation can terminate an approval and permanently preclude another application. Unlike some approvals for other Covered List categories, the robotics guidance states an application deadline but does not prescribe one fixed approval term.^[9][15]

The FCC has a continuing role after the Department's review. Under 47 U.S.C. 1601 and section 1.50003 of the FCC rules, the bureau monitors the underlying determinations and changes the list when they are modified or reversed.^[4] A device-specific Conditional Approval therefore changes the scope of the public list through a further FCC update; it is not an unpublished manufacturer self-certification.

National-security rationale and evidence

The interagency determination gave two principal reasons for the categorical action. First, it said foreign concentration in advanced-robot production and components created a supply-chain vulnerability for manufacturing, infrastructure protection, and military applications. Second, it said mobile robots' sensors, networking, remote updates, and physical actuation created opportunities for surveillance, data exfiltration, operational disruption, and remote takeover.^[2]

The determination cited concrete security reports, but those reports should not be generalized beyond their evidence. One cited 2026 incident involved unauthorized access to thousands of household robots, including camera, microphone, and home-mapping data. It also cited a disclosed vulnerability in several Unitree Robotics humanoid and quadruped models. IEEE Spectrum reported that the UniPwn exploit used a Bluetooth Low Energy Wi-Fi setup interface to obtain root-level control and could spread to other vulnerable robots in range. The publication later added Unitree's statement that it had completed most fixes and planned to distribute updates.^[2][19]

The determination separately cited reporting on an apparent backdoor in Unitree Go1 quadrupeds. Axios reported that the exposed service could reveal location and camera data and, in some configurations, permit control. It also reported that the researchers could not decide whether the design was intentional or the result of poor architecture, and included Unitree's account that it had shut down the service.^[20]

These incidents establish that serious security failures have occurred in particular connected robots. They do not independently prove that every device made outside the United States is insecure. The broader conclusion is the interagency body's national-security determination, which uses production location as a categorical proxy and routes individualized relief through Conditional Approval.^[2] That difference between documented incidents and the scope of the policy is central to understanding the action accurately.

The onshoring requirements also show that supply-chain resilience and a domestic industrial base are explicit parts of the policy, not just incidental effects.^[2][9] That does not establish the more expansive claim that the action began an inevitable economic decoupling, nor does it show that restrictions will spread to unrelated chips, investments, data, or materials. Those are forecasts, not provisions of the FCC action.

Industry and international response

The International Federation of Robotics described the measure as forward-looking and based on production location rather than manufacturer nationality. It said the definition could reach service robots, certain consumer robotic devices, warehouse systems, humanoids, and quadrupeds, while fixed industrial robot types remained expressly excluded. The organization advised affected manufacturers to examine the detailed Conditional Approval requirements.^[17]

Independent coverage frequently used ban as shorthand and emphasized the expected impact on Chinese suppliers. The Associated Press reported that Chinese officials accused the United States of overextending national-security concerns and called the measure protectionist.^[18] That response concerns the policy's perceived purpose and effects; it does not change the text, which applies the same production-based test to every manufacturer.

Several boundaries remained important as of August 19, 2026. Coverage requires a model-specific application of the device definition and domestic-end-product rule. Conditional Approval is discretionary, requires extensive disclosure and onshoring commitments, and does not replace technical FCC review. Previously authorized models remained usable and marketable under the July 28 action, subject to the narrow update waiver and any separate future proceedings. The Covered List itself can change when the Department issues approvals or when the underlying national-security determination is modified.^{[1][3][9][10]}

References

1. ^Federal Communications Commission, Public Safety and Homeland Security Bureau. "FCC's Public Safety and Homeland Security Bureau Announces Addition of Foreign-Produced Power Inverters and Advanced Robotic Devices to FCC Covered List." DA 26-786, July 28, 2026. docs.fcc.gov/...DA-26-786A1.pdf
2. ^White House-convened Executive Branch interagency body. "National Security Determination on the Threat Posed by Foreign-Produced Advanced Robotic Devices." July 27, 2026. fcc.gov/...robots-nsd.pdf
3. ^Federal Communications Commission. "Fact Sheet: FCC Updates Covered List to Include Foreign-Produced Advanced Robotic Devices and Power Inverters." DOC-423682, July 28, 2026. docs.fcc.gov/...DOC-423682A1.pdf
4. ^United States Code. "47 U.S.C. 1601: Determination of Communications Equipment or Services Posing National Security Risks." law.cornell.edu/...1601
5. ^United States Congress. "Secure Equipment Act of 2021." Public Law 117-55, November 11, 2021. congress.gov/...PLAW-117publ55.pdf
6. ^Code of Federal Regulations. "47 CFR 2.903: Prohibition on Authorization of Equipment on the Covered List." law.cornell.edu/...2.903
7. ^Code of Federal Regulations. "47 CFR 2.911: Application Requirements." law.cornell.edu/...2.911
8. ^Federal Acquisition Regulation. "48 CFR 25.101: General." law.cornell.edu/...25.101
9. ^United States Department of Defense. "Guidance on Submissions for Conditional Approval for Foreign-Produced Advanced Robotic Devices Subject to the FCC's Covered List." July 27, 2026. fcc.gov/...robots-ca.pdf
10. ^Federal Communications Commission, Office of Engineering and Technology. "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." DA 26-789, July 28, 2026. docs.fcc.gov/...DA-26-789A1.pdf
11. ^Federal Communications Commission. "Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program." 90 Federal Register 53227, November 25, 2025. govinfo.gov/...2025-21001.pdf
12. ^Federal Communications Commission, 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." DA 26-635, June 26, 2026. docs.fcc.gov/...DA-26-635A1.pdf
13. ^The White House. "Restoring the United States Department of War." Executive Order 14347, September 5, 2025. whitehouse.gov/...-united-states-department-of-war
14. ^United States Code. "10 U.S.C. 111: Executive Department." law.cornell.edu/...111
15. ^Sidley Austin LLP. "FCC Adds All Foreign-Produced Advanced Robotic Devices to the Covered List." August 7, 2026. sidley.com/...-robotic-devices-to-the-covered-list
16. ^Latham & Watkins LLP. "FCC Adds Foreign-Produced Power Inverters and Advanced Robotic Devices to the Covered List." July 31, 2026. lw.com/...nced-robotic-devices-to-the-covered-list
17. ^International Federation of Robotics. "FCC Restrictions on Foreign-Produced Advanced Robotic Devices." August 7, 2026. ifr.org/...reign-produced-advanced-robotic-devices
18. ^Chan, Ho-Him. "US Bans Foreign-Made Humanoid Robots, Targeting China over National Security." Associated Press, July 29, 2026. apnews.com/...ech-c9f5e3c94d91d00eff3b61b141fab366
19. ^Ackerman, Evan. "Exploit Allows for Takeover of Fleets of Unitree Robots." IEEE Spectrum, September 2025. spectrum.ieee.org/unitree-robot-exploit
20. ^Sabin, Sam. "Chinese Robotics Manufacturer Left Backdoor in Product." Axios, April 1, 2025. axios.com/...hinese-robots-future-of-cybersecurity