On July 28, 2026, the FCC added foreign-produced power inverters and advanced robotic devices to its Covered List, following determinations by an executive branch interagency body that they pose “unacceptable risks” to the national security of the United States. The new additions continue a string of decisions placing entire categories of foreign-produced devices on the Covered List of restricted equipment—beginning with the FCC’s December 2025 addition of all foreign-produced unmanned aircraft systems (a/k/a drones) and continuing with the March 2026 addition of all foreign-produced routers. The definitions of power inverters and advanced robotic devices are broad, seeming to reach inverters used in electrical systems such as commercial solar, battery, and wind-power projects, home solar and battery systems, and electric-vehicle chargers, and advanced robotic devices such as humanoid and quadruped robots, and robotic vacuums, pool cleaners, and lawn mowers.
The definition of “foreign-produced” also continues to remain broad. Notably, for the first time in a Covered List addition, the FCC and national security agencies have defined this key term to be synonymous with “any article that does not qualify as a ‘domestic end product’” under the Buy American Act (BAA). This change coincides with a broader push across the federal government to emphasize the BAA and other Made in USA initiatives. For additional information on the BAA, see Covington’s alert here.
Effective immediately, the addition of foreign-produced power inverters and advanced robotic devices to the Covered List prevents new models from receiving FCC equipment authorization—making them ineligible to be imported or marketed for use or sale in the United States. The ban is not absolute, however. Devices currently authorized by the FCC can continue to be imported for use and sale, absent future action to the contrary. In addition, companies can apply for “Conditional Approval” for new foreign-produced power inverters from the Department of War (DoW) or Department of Homeland Security (DHS) or new foreign-produced advanced robotic devices from DoW, which can be granted upon determination that the devices do not pose unacceptable risks. Applying for and obtaining a Conditional Approval requires submitting detailed corporate information and manufacturing and supply-chain information, and committing to some onshoring in the form of a “detailed, time-bound plan to establish or expand manufacturing in the United States” for the device or class of devices for which approval is sought.
The additions of inverters and routers followed quickly on the heels of other actions to expand use of the FCC’s equipment authorization process in service of national security and related goals. Most notably, on July 22, 2026, the FCC adopted a Report and Order and Further Notice of Proposed Rulemaking on “dangerous equipment.” The Report and Order, among other changes, expands the scope of the Covered List to include logic-based hardware components produced by covered entities and places significant new obligations on certain online marketplaces (e.g., to display the FCC ID of equipment listed). The Proposed Rulemaking seeks comment on at least 20 topics, including multiple proposals for new obligations on equipment manufacturers. These include, for example, a proposed requirement to submit software and hardware bills of materials to the FCC as part of certification applications, additional obligations on online marketplaces, and a requirement to register all self-authorized (SDoC) equipment with the FCC.
This class-based approach to the Covered List reflects the Administration’s increasing treatment of economic security and industrial policy as core national-security priorities. Like drones and routers, inverters and robotics were added to the Covered List because the Executive Branch interagency body determined that they posed a range of unacceptable national security risks, including cybersecurity vulnerabilities that could enable remote commandeering, access to sensitive personal, camera, and sensor data that can be highly valued by foreign intelligence services, and a dependence on foreign inputs that can create chokepoints exploitable by foreign actors to constrict supplies of critical components or alter or degrade functionality.
These national-security concerns are not new but instead have been steadily growing for years. We have seen the Committee on Foreign Investment in the United States (CFIUS) and Team Telecom seek to mitigate transactions presenting such risks with respect to Chinese equipment and services, including through commitments involving equipment and vendor screening, domestic manufacturing, and supply-chain integrity. The continued class-based approach to the Covered List thus marks another standalone national-security authority—like the Department of Commerce’s Information and Communications Technology and Services Program and the Department of Justice’s Data Security Program—that has grown out of risks addressed through CFIUS and concerns about the limits of its case-by-case reviews.
The real-world impacts of this class-based approach to the Covered List occur at all levels of the supply chain—from manufacturers and producers, to distributors and commercial end-users, and to investors. These class-based additions frequently mark the first time that many companies and industries are exposed to national-security regulation. A deep understanding of often-unfamiliar national security considerations and the highly technical FCC rules for equipment authorization are critical to navigating this emerging regulatory space. Companies throughout the supply chain for these devices should take steps now to ensure compliance and minimize business disruptions. Manufacturers, distributors, end-users, and investors alike should map supply chains and equipment-authorization requirements for pipelines of new products and device updates, consider contractual provisions to allocate risks related to the Covered List, and evaluate potential regulatory and policy strategies for affected devices.