The U.S. Federal Communications Commission (FCC) is accelerating its campaign to bar foreign-produced technology from the domestic market, leveraging the Secure Networks Act to target products that pose national security and supply chain risks. According to federal notices, companies manufacturing, importing, or selling items on the FCC Covered List must navigate strict prohibitions, shifting component thresholds, and complex exemption processes to lawfully enter the United States.
Understanding the FCC Covered List and National Security Determinations
The FCC Covered List identifies communications equipment and services deemed to pose an unacceptable risk to U.S. national security or the safety of U.S. persons. According to the Secure Networks Act, the agency updates this list at the direction of qualifying national security authorities, implementing determinations from agency experts regarding supply chain vulnerabilities and cybersecurity threats.
Most electronic devices require FCC equipment authorization before importation or marketing. Because covered equipment is barred from receiving these authorizations, affected devices cannot legally enter the U.S. market. However, devices that secured equipment authorization prior to a Covered List update remain authorized for import and sale, though any new model or variant requires fresh approval, according to regulatory guidelines.
Pro Tip: Existing authorizations survive, but any new model or variant will require a new authorization and will be subject to the prohibition—so refresh cycles, not current inventory, are where the risk concentrates.
Uncrewed Aircraft Systems and Critical Components
In December 2025, the FCC added foreign-produced Uncrewed Aircraft Systems (UAS) and critical components to the Covered List, citing threats from malicious actors and data collection risks associated with foreign devices, particularly those manufactured in China by companies like DJI. Within two weeks, the agency amended the rule to remove items deemed safe by the U.S. Department of War (DoW), such as products on the DoW Blue UAS Cleared List, items qualifying as domestic end products under Buy American standards (48 CFR § 25.101(a)), and toy drones.
Routers and Consumer-Grade Networking Devices
The FCC expanded the ban in March 2026 by adding foreign-produced routers to the Covered List. National Security Determinations highlighted how malicious cyber actors leverage vulnerabilities in consumer networking gear to execute attacks against American critical infrastructure, referencing incidents such as the Volt, Flax, and Salt Typhoon campaigns. The listing targets foreign-produced consumer-grade networking devices primarily intended for residential use that forward internet protocol packets and can be installed by customers.
Power Inverters and Recent DoW Revisions
Foreign-produced power inverters—devices converting direct current to alternating current—were added to the Covered List in July 2026 due to risks of compromising the U.S. electricity supply and enabling remote adversary access. However, the DoW issued a revised National Security Determination narrowing the definition.
According to the updated guidance, foreign-produced power inverters eligible for the Advanced Manufacturing Production Tax Credit (section 45X) do not pose unacceptable national security risks and are excluded from the ban because domestic production credits mean they are not properly considered foreign-produced. The updated definition also aligns utility-interactive inverters with Underwriters Laboratories Standard UL 1741 and clarifies that wired and Ethernet connections are subject to the listing.
Advanced Robotics and Operational Definitions
Also in July 2026, the FCC added foreign-produced advanced robotic devices to the Covered List, citing their growing use in defending and monitoring critical infrastructure. The agency defines an advanced robotic device as a mobile, networked robot weighing over 4.4 pounds with autonomous navigation capabilities, environmental sensors, network connectivity, and AI or machine-learning software control. Connected vehicles, medical devices, underwater vehicles, and fixed industrial robots are excluded from this definition.
How Producers Obtain a Conditional Approval Exemption
Producers of covered equipment can apply to the DoW or the Department of Homeland Security for a Conditional Approval exemption. According to federal requirements, applicants must demonstrate that their specific products do not pose national security or supply chain risks and show a commitment to building U.S. manufacturing capacity.
The application demands extensive disclosures, including:
- Corporate Structure: Legal name, ownership, beneficial owners holding 5% or greater equity, board members, executive leadership nationalities, and any foreign government influence or financing.
- Supply Chain Transparency: Detailed bills of materials, country-of-origin data for components and software, software update control entities, and identification of single points of failure.
- Onshoring Plans: A time-bound plan to establish or expand U.S. manufacturing, a dedicated compliance point of contact, and committed capital expenditures over the next one to five years.
Applications carry strict deadlines—such as January 1, 2028, for advanced robotics—and material misrepresentations result in permanent preclusion from reapplying.
Did You Know? Companies that have successfully secured conditional approvals for covered items like UAS and routers are largely headquartered or incorporated in the U.S. or allied nations, including NATO and FVEY partner countries.
Consequences of Non-Compliance and Enforcement Actions
Importing, marketing, or selling covered equipment without a valid FCC equipment authorization triggers severe enforcement measures. According to regulatory authorities, penalties include monetary forfeitures, cease-and-desist orders, and the seizure of non-compliant hardware. Furthermore, the DoW retains the authority to refer willful violations to the Department of Justice for criminal prosecution.
Recommended Compliance Steps for Affected Companies
Companies with exposure to foreign-produced technology must audit their product portfolios to identify listed components and check existing authorization statuses. Businesses should assess their “foreign-produced” status against the domestic end product test, noting that the 65% domestic component cost threshold under 48 CFR § 25.101(a)—which rises to 75% in 2029—means U.S. design alone is insufficient.
Firms anticipating the need for an exemption should assemble detailed bills of materials and onshoring plans well ahead of deadlines. Additionally, organizations must update supplier contracts, country-of-origin indemnities, and import compliance procedures to mitigate enforcement risks.
Frequently Asked Questions
What is the FCC Covered List?
The FCC Covered List is a catalog of communications equipment and services identified by national security authorities as posing an unacceptable risk to U.S. national security and public safety.
Do existing FCC equipment authorizations remain valid after a Covered List update?
Yes. Devices that received equipment authorization prior to a Covered List update remain authorized for import and sale, but any new model or variant requires a new authorization.
What happens if a company violates the terms of a Conditional Approval?
Violating the terms or misrepresenting information leads to the immediate termination of the Conditional Approval, permanent preclusion from reapplying, and potential civil or criminal penalties.
What is the domestic component cost threshold for end products?
Under 48 CFR § 25.101(a), products must meet a 65% domestic component cost threshold, which increases to 75% in 2029.
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