Robots and the Covered List: questions and answers

Is my robot covered?

The FCC uses the definition in the National Security Determination. It covers a mobile device that moves on the ground, works at a distance from a human operator based on commands or sensor data, and weighs over 4.4 pounds together with any docking or ground station.

It must also contain a sensor that perceives its surroundings, a wired or wireless connection of at least 200 kilobits per second, and software that controls its navigation, movement, perception, data collection or remote control. The definition names autonomous mobile robots, humanoid robots and quadrupeds.

The FCC has said automated guided vehicles may be covered even when they follow predefined paths, and that pool cleaning robots are not excluded. Connected vehicles, rail vehicles, uncrewed aircraft, underwater vehicles, medical devices and fixed, stationary robots such as industrial robot arms are excluded. Whether a given model is covered is decided against the definition, model by model.

My robot already has an FCC ID. Can I keep selling it?

Yes, for that model. The FCC says the change does not affect importing, marketing or selling existing models that already have FCC equipment authorization, and people can keep using the devices they own. Those devices can also keep receiving basic software and firmware updates.

The restriction falls on new models. Covered equipment cannot receive new equipment authorization, so a new model cannot be imported or sold in the United States without it.

Can a new model use the Supplier's Declaration of Conformity instead?

No. The FCC says covered equipment cannot receive any equipment authorization, including through the Supplier's Declaration of Conformity process.

What is a Conditional Approval?

It is the exception written into the Covered List entry, which reads: foreign-produced advanced robotic devices, except advanced robotic devices which have been granted a Conditional Approval by the Department of War.

The Department of War assesses each applicant for national security risk, supply chain resilience and its commitment to building manufacturing in the United States. Approved devices are named in FCC public notices, and our approvals page lists every one.

Who decides, and where does an application go?

The Department of War decides. The application is emailed as a machine-readable PDF (Portable Document Format) file to Conditional-approvals@fcc.gov, and the FCC passes it on.

Any company involved in producing the device can apply, and one application can cover a class of devices. The guidance says a submission does not guarantee approval, the Department of War may ask for more information, and its decisions are final.

What does an application have to include?

The guidance asks for the company's structure: its owners, including anyone holding five percent or more, its board and executives with their nationality, and any foreign government ownership or influence.

It asks for the supply chain: a detailed bill of materials, the country of origin of every component and of the design and software, and where the robot is made, assembled and tested.

It asks for a time-bound plan to build or expand manufacturing in the United States, with a named person or office that reports progress to the agency every quarter. An authorized officer of the company certifies that everything is complete and accurate.

What is the deadline?

The guidance says: "Applicants must submit Conditional Approval applications by January 1, 2028."

What counts as made in the United States?

A robot is foreign-produced unless it qualifies as a domestic end product under 48 CFR (Code of Federal Regulations) 25.101(a). It must be manufactured in the United States, and the cost of its domestic components must exceed 65 percent for items delivered in 2024 through 2028, and 75 percent for items delivered from 2029.

The FCC says every component counts, including commercially available off-the-shelf parts.

Does it matter who owns my company, or where it is based?

Not for whether a robot is covered. The FCC says the nationality of the company producing a device is not relevant to whether it is foreign-produced, and that the action is country neutral. What decides it is where the robot is made.

Ownership does matter in the application, which asks for owners, board members and any foreign government influence.

Is my company now on the Covered List?

No. The FCC says a company that produces robots in a foreign country is not considered identified on the Covered List. The restriction applies to the devices.

Can I still bring in units for testing, or sell to the U.S. government?

The FCC allows small batches of unauthorized devices to be imported only for product development or testing, as long as they are not marketed or sold. Importing, marketing or selling to the federal government or its agencies is exempt from the Covered List restrictions.

How long does approval take?

No processing time has been published. Robots went onto the Covered List on 28 July 2026, and the first Conditional Approval for a robot was granted on 9 September 2026. Our approvals page lists every approval since, with its date.

What does Ashore do, and what does it not do?

We assess the approval path for each product and help clients prepare the application, including a proposed U.S. production plan. We assess U.S. suppliers and contract manufacturers and introduce potential partners. The client chooses and contracts with its partners.

Our work is consulting, not legal services. The client signs, certifies and files its own application and makes every decision about its products and plan. We cannot promise approval or its timing, because the Department of War decides.