FCC Adds Foreign-Produced Power Inverters and Advanced Robotic Devices to “Covered List”

The Federal Communications Commission’s Public Safety and Homeland Security Bureau announced the addition of two new categories of equipment to the FCC’s Covered List on a prospective basis: 

1. Foreign-produced power inverters; and
2. Foreign-produced advanced robotic devices. 

The additions are based on National Security Determinations issued by an Executive Branch interagency body, convened pursuant to the Secure and Trusted Communications Networks Act of 2019, which concluded that these categories of equipment pose unacceptable risks to U.S. national security and the safety and security of U.S. persons. 

Companies that manufacture foreign-produced power inverters or advanced robotic devices should promptly assess whether their products fall within the scope of the FCC’s new Covered List designations. As a practical matter, a device assembled in the United States using predominantly foreign-sourced components may still be deemed “foreign-produced,” and thus not a “domestic end product,” if it fails the 65 percent cost of domestic components threshold. Affected companies should evaluate whether pursuing a Conditional Approval is appropriate and begin assembling the corporate, supply chain, cybersecurity, and domestic manufacturing information required to support an application. 

The addition of these devices to the Covered List applies only prospectively and does not affect the continued sale, import, use, or marketing of devices previously approved through the FCC’s equipment authorization process. 

Background

Section 2 of the Secure Networks Act directs the FCC to maintain a Covered List of communications equipment and services that pose an unacceptable risk to U.S. national security. Equipment and services on the Covered List may not receive FCC authorizations, including equipment authorizations, or be used in projects supported by federal subsidies, and U.S. providers of advanced communications services are prohibited from using federal funds to purchase, maintain, or support such equipment.

The Covered List initially focused on telecommunications, video surveillance, and cybersecurity products and services; however, the FCC has expanded the Covered List to encompass broader categories of network-connected technologies identified by the Executive Branch as presenting supply chain and cybersecurity concerns such as connected vehicle technologies. Most notably, the FCC added foreign-produced UAS and UAS critical components to the Covered List in December 2025, later refining the scope of those restrictions through subsequent updates. In March 2026, the FCC similarly added foreign-produced routers. Each of these actions included exceptions for products receiving Conditional Approvals, and the Department of War (DoW) and Department of Homeland Security (DHS) have since been implementing review processes through which manufacturers may seek product-specific or category-specific exemptions.

National Security Determinations

The Public Notice implements two National Security Determinations issued by a White House-convened interagency body and adds foreign-produced power inverters and foreign-produced advanced robotic devices to the FCC’s Covered List. 

The FCC concluded that the determinations satisfy the requirements of the Secure Networks Act, which requires inclusion of equipment determined to pose an unacceptable risk to U.S. national security; however, this prohibition applies only to new FCC equipment authorizations and does not affect previously authorized devices. That said, the FCC has separately restricted the continued importation and marketing of previously authorized equipment that was added to the Covered List in 2024 or earlier, without revoking the underlying authorizations. Accordingly, it is possible that the Commission could take similar action in the future with respect to power inverters and advanced robotic devices now subject to the Covered List.

Manufacturers may seek Conditional Approvals from DoW and DHS that exempt specific products or product categories from Covered List treatment. 

Conditional Approvals

Importantly, the FCC’s action does not operate as a blanket prohibition on all foreign-produced power inverters or advanced robotic devices. The FCC’s Public Notice expressly contemplates that manufacturers may seek individualized determinations (i.e., Conditional Approvals) that specific products or classes of products do not present the national security concerns identified in the underlying National Security Determinations. For power inverters, applications may be reviewed by either DoW or DHS; for advanced robotic devices, DoW is the reviewing agency. 

The Conditional Approval process is intended to provide a transition pathway for manufacturers willing to increase domestic manufacturing and address U.S. national security concerns. The guidance documents issued alongside the National Security Determinations require applicants to provide detailed corporate structure and manufacturing information. Applicants must also submit a comprehensive U.S. manufacturing and onshoring plan, implementation milestones, and quarterly progress reporting. Applications must be certified by a corporate officer and submitted by January 1, 2028. 

Of note, the Conditional Approval process has already proven to be a meaningful feature of the Covered List regime. Following the FCC’s addition of foreign-produced UAS, UAS critical components, and routers, DoW and DHS have issued multiple Conditional Approvals that the FCC subsequently incorporated into Covered List updates. Inclusion of a broad equipment category on the Covered List does not necessarily foreclose continued participation in the U.S. market.