Key Notes:

  • Effective July 28, 2026, the Federal Communications Commission’s (FCC) Covered List now includes foreign-produced power inverters and foreign-produced advanced robotic devices. These equipment categories are now prohibited from receiving new FCC equipment authorizations.
  • The term “foreign-produced” refers to any article that does not qualify as a “domestic end product,” as that term is defined in 48 CFR § 25.101(a). This is a reference to the Buy American requirements, which include substantial transformation and domestic content requirements.
  • A Conditional Approval process allows foreign producers to apply for a waiver to this prohibition.
  • A separate waiver by the FCC’s Office of Engineering and Technology (OET) (through Jan. 1, 2029) permits authorization holders to undertake routine software/firmware updates to previously authorized devices.

On July 28, 2026, the FCC announced the addition of foreign-produced power inverters and advanced robotic devices to the FCC Covered List. This is only the second time that the FCC Covered List has been used for a broad designation rather than naming specific entities and devices. In December 2025, the FCC added foreign-produced uncrewed aircraft systems (UAS) and UAS critical components to its Covered List.

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Photo of Francesca M.S. Guerrero Francesca M.S. Guerrero

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some…

Francesca counsels clients on compliance with export controls, sanctions, import regulations, human rights and forced labor, and the FCPA and antibribery laws. She works closely with companies to develop tailored compliance programs that fit their specific needs, and routinely advises clients on some of their most challenging international transactions, involving dealings in high-risk jurisdictions or with high-risk counterparties. Francesca also counsels companies through all phases of internal investigations of potential trade and antibribery violations and represents companies across industries before related government agencies.

Photo of Kristina Shcheglazova* Kristina Shcheglazova*

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control…

Kristina focuses her practice on advising clients on issues related to the importation and exportation of goods, including customs issues such as the classification of goods, country of origin, customs procedures and prior disclosures. She also assists clients with sanctions and export control matters, including compliance with various sanctions and export control requirements, due diligence and sanctions screenings, and advises clients on the application of U.S. sanctions and export control licensing requirements. Her experience extends to addressing issues of forced labor in supply chains, assisting clients with government contracting matters and advising on anti-corruption policies.

*Licensed in MO only, not IL; limited to federal practice only.