FCC Covered List robots and the 65% rule
Since July 28, 2026, a new foreign-produced robot can't get FCC authorization. Here's who that covers, how the 65% test is counted, and the ways through.
Ian Daily · October 23, 2026
What changed
The FCC added foreign-produced advanced robotic devices to its Covered List (DA 26-786). Covered equipment can't get an FCC equipment authorization, and without one a new robot can't be imported, marketed or sold here. Models authorized before July 28 keep selling.
Which robots it covers
- Mobile robots that move on the ground, operate at a distance from a person and weigh more than 4.4 lb.
- With a sensor, a network link of at least 200 kbps, and software that controls navigation, perception or remote command.
- That means humanoids, quadrupeds, AMRs, delivery and inspection robots. Drones, cars, rail, underwater vehicles, FDA-regulated medical devices and fixed robot arms are out.
How the 65% test works
A robot is foreign-produced unless it's a domestic end product under the Buy American rule (48 CFR 25.101(a)): made in the U.S., with U.S.-made components above 65% of component cost, rising to 75% for items delivered from 2029. Who owns the company doesn't matter.
- Count one level down. A component is whatever goes directly into the robot, U.S.-made or not as a whole.
- Component cost, not price. Bought parts at what you paid plus freight and duty; your own parts at cost plus overhead, no profit. Leave out final assembly and test.
- No allied tier. Japanese, German and Korean parts count as foreign. Off-the-shelf parts count. Unknown origin counts as foreign.
In a legged robot the joints decide it. In an illustrative quadruped with $11,800 of components, imported joints leave it at 27% domestic; the same joints made in the U.S. at the same price put it at 73%.
Run your own bill of materials
Ways through
- Federal buyers. Importing, marketing or selling to the federal government is exempt.
- Development units. Small batches can come in for development or testing (47 CFR 2.1204(a)(3)) if they aren't marketed or sold.
- Conditional Approval. The Department of War can clear a robot or class of robots. Expect to show ownership, a component-level bill of materials and a dated plan to move production here.
- Repairs. Repairing an authorized robot, or replacing parts with identical ones, isn't restricted.
Questions
Does the FCC Covered List ban robots already on sale?
No. Models authorized before July 28, 2026 keep selling. The rule stops new foreign-produced models from getting FCC equipment authorization, and without it a new robot can't be imported, marketed or sold in the U.S.
What counts as foreign-produced?
Anything that isn't a domestic end product under the Buy American test: made in the U.S., with U.S.-made components above 65% of component cost (75% for items delivered from 2029). Who owns the company doesn't matter.
Do Japanese or German parts count as domestic?
No. The test has no allied tier. Only parts manufactured in the U.S. count on the domestic side; parts of unknown origin count as foreign.
Is there any way through for a foreign-produced robot?
Sales to the federal government are exempt, small development batches can come in if they aren't marketed or sold, repairs with identical parts aren't restricted, and the Department of War can grant Conditional Approval.
Sources: FCC Public Notice DA 26-786 and the FCC's Covered List FAQ; 48 CFR 25.101(a) and 25.003. Law firms differ on the later threshold (some read 70%); the FAR schedule says 75%. This explains the rule; it isn't legal advice. Longer write-up.