China/United States: FCC Expands Restrictions on Foreign-Produced Advanced Robots and Power Inverters

The US Federal Communications Commission (FCC) has expanded its Covered List to include certain foreign-produced advanced robotic devices and power inverters, introducing significant new considerations for manufacturers seeking access to the US market.

The measures, announced in July 2026, form part of the FCC’s continued efforts to address national security risks within communications and connected technology supply chains.

Importantly, the evolving FCC approach increasingly focuses on where equipment is produced, rather than solely on the identity of a particular manufacturer or supplier.

What Equipment Is Covered?

The new measures extend to certain advanced robotic devices, including autonomous mobile robots, humanoid robots and quadruped robots.

Covered equipment generally includes mobile mechanical devices capable of autonomous movement, obstacle avoidance or navigation and which incorporate connected technologies such as Wi-Fi, Bluetooth, cellular or satellite communications.

The rules exclude several categories, including certain connected vehicles, unmanned aerial vehicles, underwater unmanned vehicles, surgical devices, mobility aids and stationary industrial or medical robots.

The FCC has also added certain power inverters to the Covered List, including micro, string, centralised and hybrid inverters incorporating remote communication, control, sensing, data collection or monitoring capabilities.

Impact on New and Existing Products

The distinction between new and existing equipment models is particularly important.

In principle, newly covered foreign-produced robotic equipment and power inverter models may no longer be eligible for FCC equipment authorisation, potentially preventing their entry into the US market for sale or distribution.

Existing models that have already received FCC authorisation may, however, continue to be imported, sold and used.

To minimise disruption for existing users, the FCC has also provided a limited transitional waiver allowing previously authorised devices to receive certain necessary software and firmware updates until at least 1 January 2029.

Businesses should nevertheless monitor product modifications carefully. Material hardware, firmware or other changes may trigger a requirement for a new FCC authorisation.

A Shift Towards Production-Based Regulation

Historically, the FCC Covered List focused primarily on particular manufacturers and service providers considered to present unacceptable national security risks.

Recent FCC measures indicate a broader shift towards restrictions based on production location.

This creates a potentially wider compliance burden for international manufacturers because businesses may need to determine not only who manufactures or supplies their products, but also where design, production, assembly and key component activities take place.

For companies with complex international production arrangements, this could make supply-chain traceability increasingly important.

Supply Chain and Manufacturing Considerations

Companies affected by the measures should consider establishing detailed records covering their products and manufacturing arrangements.

Relevant information may include:

• product models and FCC identification numbers;

• equipment authorisation methods;

• manufacturing and final assembly locations;

• key hardware and component suppliers;

• software and firmware sources;

• testing information;

• importers and US distribution arrangements; and

• planned changes to existing product models.

The FCC is also considering broader supply-chain disclosure requirements under which equipment certification applicants could be required to disclose hardware and software bills of materials, manufacturers, production locations and the relative value of individual components.

Changes to hardware, software, firmware, suppliers or production locations could also become subject to continuing notification requirements.

Conditional Approval

For certain foreign-produced advanced robotic equipment, businesses may be able to seek conditional approval.

Such applications are expected to involve a detailed assessment of national security and supply-chain risks and may require extensive disclosure of corporate ownership, product components, software, manufacturing and testing locations, as well as proposed US manufacturing arrangements.

Companies considering this route should therefore assess the commercial and compliance implications carefully, particularly as approval is not guaranteed.

For Chinese businesses, any disclosure of technology, software, technical information or related data should also be considered alongside applicable Chinese export control and data-transfer requirements.

What Businesses Should Do

Manufacturers supplying connected robotic equipment, power inverters or related technology into the United States should review their current and planned product portfolios and distinguish clearly between existing authorised models and future models.

Businesses should also assess whether product upgrades or supply-chain changes could trigger new equipment authorisation requirements.

More broadly, the FCC’s movement towards production-location and supply-chain-based regulation illustrates an increasing regulatory focus on the entire technology supply chain rather than simply the identity of individual manufacturers.

For companies operating between China and the United States in particular, coordinated review of FCC compliance, manufacturing arrangements, supply-chain documentation and Chinese export control requirements will become increasingly important.

Anjie Broad, China, a Transatlantic Law International Affiliated Firm.  

For further information or for any assistance please contact china@transatlanticlaw.com

Disclaimer: Transatlantic Law International Limited is a UK registered limited liability company providing international business and legal solutions through its own resources and the expertise of over 105 affiliated independent law firms in over 95 countries worldwide. This article is for background information only and provided in the context of the applicable law when published and does not constitute legal advice and cannot be relied on as such for any matter. Legal advice may be provided subject to the retention of Transatlantic Law International Limited’s services and its governing terms and conditions of service. Transatlantic Law International Limited, based at 84 Brook Street, London W1K 5EH, United Kingdom, is registered with Companies House, Reg Nr. 361484, with its registered address at 83 Cambridge Street, London SW1V 4PS, United Kingdom.