Foreign-Produced Advanced Robotic Devices and Certain Foreign-Produced Power Inverters Added to FCC Covered List

The Federal Communications Commission (FCC) has added foreign-produced advanced robotic devices and certain foreign-produced power inverters to its list of equipment and services that have been determined to pose “an unacceptable risk to the national security of the United States or the security and safety of United States persons” (the Covered List). Equipment on the Covered List cannot receive a new FCC equipment authorization, whether through certification or the Supplier’s Declaration of Conformity process. Because most electronic devices require FCC equipment authorization before U.S. importation, marketing or sale, the listing generally prevents new covered models from entering the U.S. market.

Key Provisions

• Foreign-produced advanced robotic devices and certain foreign-produced power inverters can no longer receive new FCC equipment authorizations, generally preventing new covered models from being imported, marketed or sold in the U.S. absent conditional approval.
• The FCC’s category-based listings turn on place of production, not the producer’s nationality.
• The July 28, 2026, action does not revoke prior equipment authorizations. Models authorized before July 28, 2026, may continue to be imported, marketed, sold and used, and qualifying software and firmware updates remain permitted under an FCC waiver through at least January 1, 2029.

What Advanced Robotic Devices are Covered?

The FCC’s action covers any foreign-produced “mechanical mobile device,” including autonomous mobile robots, humanoid robots and quadrupeds, that: (i) is capable of locomotion, obstacle avoidance, navigation or other movement on the ground; (ii) is designed to operate at a distance from a human operator or supervisor based on commands or sensor data; (iii) has a combined weight, including any ground or docking station, of more than 4.4 pounds; and (iv) contains a sensor capable of perceiving its environment, wired or wireless network connectivity of at least 200 kbps, and software, running locally or remotely, that controls autonomous navigation or movement, perception, data collection or remote command-and-control.

The FCC’s action excludes, among other devices, connected vehicles, rail-only vehicles, uncrewed aircraft, unmanned underwater vehicles, certain FDA-regulated medical devices and fixed/stationary robots intended for industrial or medical use.

What Power Inverters are Covered?

Following an update on August 20, 2026, the FCC’s action covers foreign-produced utility-interactive inverters (including bidirectional devices) that convert DC power to AC power for use in parallel with an electric utility and that contain — or are designed, equipped or configured to accept — a component enabling remote communication, control, sensing, data collection or monitoring through wired or wireless connectivity, including Ethernet, Wi-Fi, cellular or Bluetooth. The FCC also clarified that inverters eligible for the Section 45X Advanced Manufacturing Tax Credit are not treated as “foreign-produced.”

What is Foreign-Produced?

An advanced robotic device is “foreign-produced” if it does not qualify as a “domestic end product” under the federal Buy American rules. Generally, a product qualifies as a domestic end product if it is manufactured in the U.S. and the cost of its domestic components exceeds 65% of total component costs for items delivered in calendar years 2024 through 2028, increasing to 75% beginning in calendar year 2029.

A power inverter is “foreign-produced” only if it neither qualifies as a “domestic end product” nor is eligible for the Section 45X Advanced Manufacturing Tax Credit.

What Should You Do Now?

Manufacturers, importers, distributors and purchasers of affected advanced robotic devices and power inverters should assess each product line to determine whether it meets the applicable technical definition, is “foreign-produced” and already has FCC equipment authorization. For new covered models, producers should consider seeking conditional approval from the Department of Defense (for advanced robotic devices) or the Departments of Defense or Homeland Security (for power inverters); current guidance requires applications by January 1, 2028. Companies dealing with grid-connected inverters should also monitor implementation of a separate Executive Order issued on August 26, 2026, authorizing the Department of Energy to restrict certain transactions involving foreign-produced bulk-power system equipment when specified foreign-supplier and national-security risk criteria are met.