The Covered List, and the hardware you were about to buy

Hardware has always carried supply risk. The newer part is that one federal notice can take a whole category of connected machines off the US market, without naming a single manufacturer. On 22 December 2025 the FCC added uncrewed aircraft systems and UAS critical components produced in a foreign country to its Covered List [3]. On 28 July 2026 it did the same to foreign-produced advanced robotic devices and foreign-produced power inverters [1]. Neither action was aimed at a company. Both were aimed at a category, and the category was defined by where the thing was built.

This guide is for the operator buying one machine, or three: a drone for roof and site photos, a mobile robot for a small warehouse, an inverter for the shop roof, a quadruped for a demo you are trying to win work with. It is about how the mechanism works, what it actually stops, and how to buy so that a notice you did not see coming costs you a delay instead of a business process. It is not for importers, resellers, federal contractors, or anyone running a fleet. Those cases turn on customs classification, procurement clauses and waiver filings, and they need a lawyer rather than a guide.

The rule blocks the next unit, not the one you own

The Covered List is the list the FCC maintains for equipment and services with certain capabilities enumerated in section 2(a) of the Secure and Trusted Communications Networks Act of 2019 [4]. For its first years it named companies: Huawei, ZTE, Hytera, Hikvision and Dahua on 12 March 2021, AO Kaspersky Lab in March 2022, Kaspersky Lab, Inc. in July 2024 [4]. What turns a listing into a market ban is a separate law. The Secure Equipment Act of 2021, Public Law 117-55, approved 11 November 2021, directs the FCC to clarify that it “will no longer review or approve any application for equipment authorization for equipment that is on the list of covered communications equipment or services” [5].

Equipment authorization is the permission slip a radio-emitting device needs before it can legally enter the US market. New foreign-produced advanced robotic devices and power inverters are, in the FCC’s own words, “generally prohibited from receiving FCC authorization to be imported, marketed, or sold in the U.S.” [2]. That is the whole mechanism. It is a paperwork gate at the border and the point of sale, not a rule about what you may own or operate.

Which is why the same fact sheet says the update “does not prohibit the import, sale, or use of any existing models of advanced robotic device and power inverters the FCC previously authorized” [2]. The machine on your bench keeps working. It stays legal to use. It stays legal to resell. The drone you bought in 2024 is not contraband and nobody is coming for it. What ended is the arrival of new models of that kind through the front door.

The definitions are wider than the pictures in the news

The coverage announced in July 2026 reads, in the operative entry, as “Foreign-produced advanced robotic devices, except advanced robotic devices which have been granted a Conditional Approval by DoW” [1]. The notice does not write the definitions itself. It says the Commission accepts “the National Security Determinations’ definitions of ‘foreign-produced,’ ‘power inverters,’ and ‘advanced robotic devices,’ as provided in the Appendices” [1], and the definitions are where the surprise lives.

A covered device is a mechanical mobile device capable of locomotion, obstacle avoidance, navigation or ground movement, operating remotely from human control or in response to sensor data, with a combined device-and-station weight above 4.4 pounds, containing three things: a sensor for perceiving its environment, network connectivity of at least 200 kbps in either direction, and software controlling autonomous navigation, perception, data collection or remote command [6]. Four and a half pounds and 200 kbps is a low bar. The category is written to reach “autonomous mobile robots, humanoid robots, and quadrupeds” by name [6], and in practice that means “consumer household robots above the weight threshold, warehouse autonomous mobile robots, sidewalk delivery robots, inspection quadrupeds, and humanoid platforms” [7].

The named exclusions are specific and worth knowing: connected vehicles, rail-operated vehicles, uncrewed aircraft systems (already listed separately), unmanned underwater vehicles, FDA-regulated medical devices, and fixed, stationary industrial robots of the articulating, parallel or delta, Cartesian or gantry, and SCARA types [6]. A welding cell bolted to a floor is out. Something that drives itself around your unit and phones home is in.

Definitions also move after the fact. On 20 August 2026, three weeks after the original notice, the FCC narrowed the covered power inverter definition to those “intended for use in parallel with an electric utility to supply common loads and sometimes deliver power to the utility, i.e., a utility-interactive inverter as that term is defined in UL 1741” [6]. If you asked the question in July, the answer you got may not be the answer in September.

”Foreign-produced” is a content test, not a flag on the box

The listings do not name China, or any country. “Foreign-produced” means an article that does not qualify as a domestic end product under the Buy American standard at 48 C.F.R. § 25.101 [6]. That standard is arithmetic on a bill of materials, and the threshold is 65 percent domestic content for items delivered through 2028, rising to 75 percent in 2029 [7].

Two consequences follow, and both are counterintuitive. A device from a well-known American brand can be foreign-produced if enough of what is inside it was made elsewhere. And a device from a company headquartered abroad can clear the test if it is genuinely built here. Brand nationality tells you nothing. The percentage tells you everything, and the percentage is a number the vendor either has or does not have.

So the useful question to a salesperson is not where they are based. It is what share of component cost in this model is domestic, and whether they will put that in writing. A vendor who has done the analysis will answer in a sentence. A vendor who has not will talk about headquarters, engineering teams and final assembly. That answer is itself information.

Grandfathering runs per model, and it stops at the firmware

The listing operates prospectively, and previously authorized models keep their authorization [2][7]. The unit of grandfathering is the individual model, so the instruction from counsel is to “verify grandfathered status at the model and FCC ID level” [7], not at the brand or the product line. A vendor can have one grandfathered model and three that will never be authorized, and the marketing page will not distinguish them. A product that was already built or sitting in inventory before 28 July 2026 but had not yet received its authorization is not grandfathered either [7].

There is a second limit that matters more than most buyers realise. On the day of the listing, the FCC’s Office of Engineering and Technology waived the prohibitions for Class I and Class II software and firmware updates that mitigate harm to US consumers, at least until 1 January 2029 [7]. The waiver suspends only the prohibitions, the ordinary permissive change requirements still apply, and hardware changes fall outside it entirely [7]. A grandfathered model can therefore be patched but not meaningfully revised. There is no hardware refresh coming, and when the component supply behind it runs down, the model quietly ends. Vendors seeking the Conditional Approval route out of the listing have their own cutoff: applications are required by 1 January 2028, and missing it forecloses that pathway [7].

Read those two facts together and the exposure becomes clear. It is not the machine you own. It is the second machine, the replacement after a drop, and the part that is only made for a model nobody is allowed to re-authorize.

What to ask before you sign, and what to put in the contract

Ask for the model’s FCC ID and the date its authorization was granted, in writing, before you pay. That single data point tells you whether you are buying a grandfathered model or a bet. Ask for the domestic content share. Ask who supplies spare parts, for how many years, and what happens when they stop. Then put the answers in the order, because a specification sheet is not a commitment and a support page is not a contract.

Two contract terms are worth the friction. First, a delivery term that says who bears the loss if the model cannot lawfully be imported between order and delivery. A categorical listing does not name the manufacturer you ordered from, so nobody in the chain gets a warning addressed to them. Second, a substitution right: if the ordered model becomes unavailable, you can take an equivalent or take your deposit back, at your option rather than theirs.

The public notices themselves are published in full and free to read [1][3]. If you want a second pass over one, paste the notice into Claude or Perplexity and ask which of the definitions your specific device meets, then check each answer against the text of the notice before you rely on it. The definitions are the part people get wrong, and they are also the part a model can quote back to you accurately if you give it the source.

Price the second unit before you buy the first

The prices that make small physical AI projects viable are public, and they are low. Unitree’s own store lists the Go2 from $1,600, with $2,800 shown on the Go2 product page, before shipping of $399 to $1,000 [8]. If a number in that range is what made your project viable, then the project has a single point of failure that is not technical and not commercial. It is regulatory, and you cannot negotiate with it.

The fix is boring. Decide, before you buy, what you would spend to replace the machine from a supplier who is not exposed to the same listing, and set that money aside over the life of the deployment. If the replacement number is one you would never actually spend, you have learned something useful: the process you are about to build on this machine should stay a process you can also do without it.

What still goes wrong

You often cannot tell what you own. Grandfathered status has to be verified at the model and FCC ID level [7], and if a vendor does not publish the FCC ID next to the model name, or ships several hardware revisions under one product name, you are reconstructing it from the label on the machine. If you bought through a marketplace reseller, tracing the actual authorization can take longer than the purchase did. Keep the invoice and a photograph of the FCC ID label together, because reconstructing them a year later is unpleasant.

The secondhand market is a real option and a real trap. Existing previously authorized models remain legal to import, sell and use [2], so a used unit is a legitimate purchase. It simply arrives with no parts pipeline behind it, and a grandfathered model can receive software and firmware updates but not hardware changes [7]. You are buying the machine and the end of its road at the same time. That can still be the right call for a one-off job. It is the wrong call for something you intend to run daily for three years.

Finally, this guide has a shelf life by design, and so does the official page. The Covered List has grown from five named companies in 2021 [4] to whole categories of uncrewed aircraft in December 2025 [3] and robots and inverters in July 2026 [1], and the inverter definition was revised three weeks after publication [6]. The FCC’s consolidated Covered List page is free to read, but on 4 September 2026 it still carried a last-updated date of 3 September 2024 and showed only the named companies, without the drone, robot or inverter entries [4]. The public notices are the current record, so read those, on the day you are about to spend money [1][3]. And none of this is legal advice; if you are importing, reselling, or selling into government, get counsel before you rely on any of it.