FCC Approvals- The New Rules-Can Your New Connected Product Still Get FCC Approval? What Engineers Need to Know About the New Robot and Power Inverter Rules
For decades, getting an electronic product ready for the U.S. market followed a reasonably understandable path.
Design the product.
Test it.
Make sure its radio-frequency emissions and wireless functions meet Federal Communications Commission requirements.
Obtain the appropriate FCC equipment authorization.
Start selling it.
For companies developing certain robots and connected power equipment, the FCC process just became considerably more complicated
On July 28, 2026, the FCC added two broad categories to its Covered List:
- foreign-produced advanced robotic devices
- foreign-produced connected power inverters
That means certain new products in those categories, for instance, robot mowers or vacuum cleaners, generally cannot receive the FCC equipment authorization needed to enter the U.S. market unless they qualify as a U.S. domestic end product or receive Conditional Approval. (docs.fcc.gov)
And here is the part product developers need to understand immediately:
Passing the technical FCC tests may no longer be enough.
Before worrying about whether a new product passes RF or EMC testing, a manufacturer may first need to determine whether that product is even eligible to receive FCC authorization.
What Should a Company Developing a New Product Do Now?
If you are developing a robot, connected power inverter or another product that could fall under these new rules, do not wait until final FCC testing to investigate this.
This may now be an early product-development question.
Before freezing the design, signing a manufacturing agreement, ordering tooling or committing to a U.S. launch date, determine:
- Is this product likely to fall within the FCC’s definition of an advanced robotic device or covered power inverter?
- Will it qualify as a U.S. domestic end product?
- Where will final manufacturing occur?
- Where do the major components come from?
- Who controls the firmware and software?
- Will the product require Conditional Approval?
- What documentation will be needed to prove manufacturing and component origin?
- Can the launch schedule tolerate an approval process that may not have a guaranteed completion date?
If any of those answers are unclear, keep reading.
The rest of this article explains why these questions matter, who makes the decisions, what Conditional Approval means, what companies may have to disclose, and what manufacturers should ask before betting a product launch on the new process.
First: What Does Normal FCC Approval Do?
The FCC regulates radio-frequency devices because poorly designed electronics can interfere with communications systems.
Depending on the product, equipment authorization generally occurs through one of two procedures:
Supplier’s Declaration of Conformity (SDoC) or Certification.
Certification is the more rigorous route and is typically required for RF equipment with greater potential to cause harmful interference. Certification applications are reviewed by FCC-recognized Telecommunications Certification Bodies, or TCBs. (fcc.gov)
A product containing Wi-Fi, Bluetooth, cellular communications or other radio transmitters will commonly encounter FCC requirements somewhere during development.
Manufacturers therefore already know—or should know—to budget time for compliance testing, documentation, labeling and authorization before commercial launch. The FCC generally prohibits marketing RF devices that have not satisfied the applicable equipment-authorization requirements. (fcc.gov)
The new rules do not replace that process.
They add another question ahead of it.
The New Question: Is the Product Allowed to Receive FCC Authorization?
This is where the Covered List comes in.
The FCC maintains a list of equipment and services that have been determined to pose an unacceptable risk to U.S. national security or the safety and security of U.S. persons.
Equipment on that list generally cannot receive a new FCC equipment authorization. (docs.fcc.gov)
On July 28, foreign-produced advanced robotic devices and connected power inverters joined that list. (docs.fcc.gov)
That creates two different compliance questions:
Question 1: Does our product technically comply with FCC requirements?
and now:
Question 2: Is our product eligible to receive FCC authorization in the first place?
A manufacturer needs satisfactory answers to both.
What Is an “Advanced Robotic Device”?
The government’s definition is much broader than a humanoid robot walking around a factory.
A covered advanced robotic device generally must be a mechanical mobile device that:
- can move, navigate or avoid obstacles on the ground;
- operates at a distance from a human operator based on commands, sensor information or both;
- weighs more than 4.4 pounds, including an applicable docking or ground station; and
- contains environmental sensing, network connectivity of at least 200 kbps, and software or firmware controlling functions such as navigation, perception, data collection or remote command and control. (fenwick.com)
The definition can encompass autonomous mobile robots, humanoids, quadrupeds and wheeled or tracked robotic platforms. (sidley.com)
For consumer-product developers, that is why this rule deserves attention.
A robot does not have to look like R2-D2 to potentially qualify.
A connected autonomous machine moving around a house, lawn, warehouse or other environment may fit the definition.
That can potentially bring products such as robotic lawn equipment and household service robots into the discussion, in addition to warehouse AMRs, delivery robots, inspection robots, humanoids and robotic quadrupeds.
The safest approach is to compare the actual characteristics of the product against the FCC definition rather than relying on whatever marketing category appears on the box.
Some Robots Are Specifically Excluded
The government did create important exclusions.
Among them are:
- connected motor vehicles covered by separate Commerce Department rules;
- vehicles that operate only on rails;
- uncrewed aircraft systems, which are handled separately;
- unmanned underwater vehicles;
- certain regulated medical and mobility devices; and
- fixed, stationary industrial and medical robots, including many traditional articulated, Cartesian, delta and SCARA robot arms. (fenwick.com)
That last distinction is important for industrial automation companies.
A traditional robot arm bolted to a manufacturing cell is not being treated the same way as an autonomous mobile robot driving around the factory.
Power Inverters Are Included Too
The second July 28 category may initially seem unrelated to robotics.
It isn’t.
Connected power inverters are increasingly intelligent, remotely accessible devices embedded throughout solar-generation systems, battery-storage systems and the electrical grid.
The FCC action covers foreign-produced connected inverter systems capable of converting DC power to AC or AC to DC and containing remote communication, monitoring, control, sensing or data-collection capabilities.
The definition can encompass microinverters, string inverters, central inverters and hybrid battery-based inverters. (fenwick.com)
The government’s stated concern is not ordinary electrical safety. It is the combination of connectivity, cybersecurity and dependence on foreign supply chains for equipment that increasingly controls important infrastructure. (docs.fcc.gov)
Does “Foreign-Produced” Mean Chinese?
No.
This is one of the most important details for product developers.
The rule is not simply a ban on Chinese-manufactured robots.
For this action, the government defines foreign-produced by referring to the Buy American Act’s definition of a domestic end product.
Generally, that means a product must be manufactured in the United States and meet a domestic-component-cost threshold. The threshold is currently 65% through 2028 and is scheduled to rise to 75% beginning in 2029. (sidley.com)
That means an American company could design a robot in California and manufacture it in Japan, Germany, Mexico or another allied country and still potentially have a foreign-produced product for purposes of this rule.
Conversely, a foreign-owned company manufacturing an eligible product in the United States with sufficient domestic content might potentially fall outside the foreign-produced category.
So this is not simply a question of where company headquarters are located.
Where the product is manufactured and where its component value originates can matter.
So Who Actually Put These Products on the FCC Covered List?
This is probably the most confusing part of the whole process.
Think of the FCC as the agency responsible for keeping and enforcing the list, while Congress has authorized certain national-security authorities to make determinations that can cause equipment to be added to it.
Under the Secure and Trusted Communications Networks Act, when an authorized national-security source makes the required determination that equipment poses an unacceptable national-security risk, the FCC is required to incorporate that determination into the Covered List.
The FCC has previously explained that Congress’s use of the words “shall place” means the agency does not simply have discretion to ignore a qualifying national-security determination. (docs.fcc.gov)
For the July 2026 action, a White House-convened Executive Branch interagency body containing national-security agencies made the determinations concerning foreign-produced advanced robotic devices and power inverters.
The FCC then implemented those determinations by updating its Covered List. (docs.fcc.gov)
So, in simplified form:
National-security authorities evaluate the risk.
↓
A national-security determination is made.
↓
The FCC updates its Covered List.
↓
Covered equipment generally becomes ineligible for new FCC equipment authorization.
That is what people mean when they say the FCC does not simply decide on its own what belongs on the Covered List.
The FCC remains the highly visible agency enforcing the result, but the underlying national-security determination may originate elsewhere in government.
Then What Is Conditional Approval?
Conditional Approval is essentially a pathway for a foreign-produced product that would otherwise fall within the Covered List to receive an individualized determination that it does not present the unacceptable risks identified by the government.
For advanced robotic devices, the national-security determination is associated with the Department of War.
For connected power inverters, the Department of War or Department of Homeland Security may be involved. (docs.fcc.gov)
The terminology itself deserves explanation.
The Department of War is the Department of Defense using a secondary title authorized by a September 2025 executive order. The statutory Department of Defense name remains legally controlling unless Congress changes it. (whitehouse.gov)
Manufacturers do not simply send their robot to the Pentagon for another emissions test.
Conditional Approval is not normal FCC certification.
It is a national-security and supply-chain review.
The manufacturer submits through the process identified by the FCC, and the appropriate Executive Branch authorities evaluate whether the specific product or product class should be exempted from the Covered List restriction. (docs.fcc.gov)
If the appropriate national-security authority determines that the product does not present the identified unacceptable risk and communicates that determination to the FCC, the product can potentially proceed toward ordinary equipment authorization.
That means Conditional Approval does not replace normal FCC testing either.
It may simply allow the manufacturer to get to that next step.
What Does a Company Have to Disclose?
This may be the biggest practical surprise for engineering companies.
Conditional Approval is not based simply on an emissions report.
Government guidance calls for extensive information about the applicant and product, including corporate, investor, manufacturing and supply-chain information.
Companies considering Conditional Approval should expect scrutiny of subjects such as:
- corporate structure and ownership;
- investors and beneficial ownership;
- manufacturing locations;
- suppliers and supply-chain dependencies;
- product design origin;
- software and firmware origin;
- bills of materials and component sourcing;
- sole-source or concentrated suppliers;
- current U.S. operations; and
- plans to establish or expand U.S. manufacturing. (fenwick.com)
The robotics guidance also asks applicants to describe a detailed, time-bound U.S. production expansion plan, including anticipated hiring, manufacturing-space expansion and investment. (sidley.com)
That means supply-chain information that once lived primarily in procurement, ERP or PLM systems may suddenly become part of regulatory market access.
For engineering organizations, that may be one of the most consequential changes in this entire story.
How Long Does Conditional Approval Take?
At the moment, this is one of the questions companies should not pretend has an easy answer.
The government has published a process and application requirements, but there is not a simple guaranteed review period comparable to saying, “Allow 30 days for approval.”
Applicants should also expect that government reviewers may ask follow-up questions during the evaluation. (fenwick.com)
For advanced robotic devices, current guidance says applications for this Conditional Approval pathway must be submitted by January 1, 2028. (sidley.com)
That is very different from ordinary product planning in which a team might reserve several weeks near the end of development for FCC testing.
If your entire U.S. launch depends on Conditional Approval, the practical lesson is straightforward:
Treat this as an early program risk, not a final certification task.
What About Products That Were Already Approved?
This rule primarily affects new equipment authorizations.
The FCC says previously authorized models are not suddenly prohibited from being owned, used, imported, marketed or sold merely because their broader product category was added to the Covered List. (docs.fcc.gov)
There was, however, another complication.
Rules affecting Covered List equipment could have prevented certain software and firmware changes to previously authorized equipment.
That could create an obvious cybersecurity problem if manufacturers were unable to patch vulnerabilities in products already deployed.
The FCC therefore issued a waiver allowing qualifying software and firmware updates to previously authorized advanced robotic devices and power inverters at least through January 1, 2029. (docs.fcc.gov)
That distinction between an existing authorized model and a new model seeking authorization may become increasingly important to engineering and product-management teams.
Questions to Ask Before Betting a Product Launch on Conditional Approval
Because this process is new, companies should not be afraid to ask very basic questions before committing millions of dollars to tooling, manufacturing, inventory or marketing.
Ask the FCC, appropriate agency, compliance adviser or legal counsel:
Who actually makes the final determination on our application?
What specific criteria will be used to approve or deny our product?
Which criteria are mandatory and which involve agency discretion?
What documentation will we need to prove component origin and manufacturing location?
How is domestic-content percentage calculated for our particular BOM?
How long should we realistically budget for review?
Is there a target or maximum review period?
Will we receive status updates while the application is pending?
What happens if the application is denied?
Is there an administrative appeal or reconsideration process?
Will the government explain why an application was denied?
Are approvals public? Are denials public?
How will confidential BOM, supplier, ownership and manufacturing information be protected?
Can conditions be attached to an approval?
Could changing a supplier, component, manufacturing site or firmware source invalidate an approval?
Does U.S. assembly alone help, or must the product satisfy the full domestic-end-product test?
How are products manufactured in allied countries treated?
What happens when two competing manufacturers with similar products receive different determinations?
Are there government application fees?
Are outside assessors, laboratories, consultants or other third parties required?
Are any specific contractors or approved organizations required to participate in the process?
What U.S. manufacturing commitments will the government expect?
How will those commitments be monitored after approval?
And perhaps most importantly:
What could change between now and our planned product launch?
Those are not political questions.
They are product-development questions.
A company deciding whether to invest in a new robot or connected energy product needs to understand the rules governing whether it will actually be able to sell that product.
Why This Matters to Engineering Teams, Not Just Compliance Departments
It would be easy to treat this as something for the legal department.
That may be a mistake.
Consider how many engineering decisions can affect the answers:
A component substitution changes the BOM.
A firmware team moves development to another supplier.
Manufacturing shifts from one country to another.
A low-cost sensor comes from a new source.
A contract manufacturer changes a subassembly supplier.
A robot gains a cellular modem late in development.
A product that began as a manually controlled machine gains autonomous navigation.
Those may once have been viewed primarily as engineering, cost or procurement decisions.
Under a compliance regime that considers manufacturing origin, software, firmware and supply-chain provenance, they may also affect regulatory eligibility.
That means the engineering organization, procurement, cybersecurity, regulatory compliance, legal and product management may need to talk to one another much earlier.
This Is Bigger Than Robot Mowers
Robot lawn mowers may be the product that causes consumers to notice the new FCC policy.
But engineers should pay attention to the larger change.
The FCC Covered List has expanded beyond named telecommunications companies and specific communications products. Recent additions have included foreign-produced uncrewed aircraft systems, routers, advanced robotic devices and power inverters. (docs.fcc.gov)
At the same time, the FCC has been examining how components inside otherwise authorized electronic products may create Covered List concerns. (docs.fcc.gov)
That suggests a broader shift in compliance thinking.
For many connected products, engineers historically asked:
Does it work?
Is it safe?
Does it comply with EMC and RF requirements?
Can we manufacture it?
Now another question may need to join the list:
Where did the product—and the technology inside it—come from?
That brings component provenance, manufacturing location, firmware ownership, cybersecurity and supply-chain visibility much closer to the engineering design process.
The Bottom Line
The July 2026 FCC action does not mean Americans have to throw away their robot vacuums, lawn robots or existing connected energy equipment.
Nor does it mean that every foreign component automatically makes an electronic product illegal.
But companies developing new products need to understand that ordinary FCC technical compliance may no longer be the only gate between a finished design and the U.S. market.
For certain foreign-produced robots and connected power inverters, there is now another gate involving manufacturing origin, supply-chain risk and national-security review.
And that means the question:
“Can we get FCC approval?”
needs to be asked much earlier than it used to be.
Before the tooling.
Before the manufacturing contract.
Before the inventory.
Before the launch campaign.
And preferably before someone has to walk into a product-development meeting and explain that the beautifully engineered product sitting on the table may not yet be eligible to receive the FCC authorization required to sell it.
EngineeringSoftwareTrials.com provides engineering and technology information, not legal advice. Companies affected by these rules should verify current FCC guidance and obtain appropriate regulatory or legal advice before making product-launch or compliance decisions.
