FCC Covered List 2026: Inverters and Robotics

As at 18 September 2026

The US is tightening market access for certain inverters and robotic devices manufactured abroad. On 28 July 2026, the Federal Communications Commission (FCC) added both product categories to its „Covered List“. New models covered by these entries will, in principle, no longer be able to obtain FCC device authorisation unless an exemption applies. The restrictions are not limited to Chinese products: German manufacturers and their US distribution partners may also be affected.

However, this is not a blanket ban on all inverters and industrial robots. The decisive factors are the specific product definitions, the production conditions and the current approval status. It is particularly important to note that the FCC significantly amended the entry for inverters as early as 20 August 2026. An assessment based solely on the original July announcement may therefore lead to incorrect conclusions.

What is the FCC Covered List – and what are the implications of inclusion on it?

The FCC Covered List sets out communications equipment and services which, according to the relevant US security assessments, pose an unacceptable risk to national security or the safety of US persons. Its legal basis is the Secure and Trusted Communications Networks Act of 2019. In particular, 47 CFR § 2.903(a) prohibits the granting of FCC equipment authorisation for listed devices.

The practical implication is that if a new product requires such authorisation, its inclusion on the Covered List may prevent its regular import and distribution in the US. The regulatory review therefore does not end with technical test reports. The question of whether the product may be authorised at all also becomes a crucial part of the US market launch.

The underlying security assessments cite, amongst other things, potential remote shutdowns, unauthorised access, data leaks and reliance on foreign supply chains. In the case of inverters, the focus is particularly on the energy infrastructure; for networked robots, potential for monitoring and tampering is also a concern. These are the risks cited by the US authorities – not a finding that every affected product actually has a security vulnerability.

Which inverters are affected?

Since the amendment of 20 August 2026, two key conditions have been essential:

Firstly, it must be a grid-connected inverter. The definition covers so-called utility-interactive inverters, as defined in UL 1741: devices that convert direct current into alternating current and are designed for parallel operation with the public electricity grid. Bidirectional devices may also fall within this definition.

Secondly, the device must have the relevant communication functions or be equipped to support them. The scope covers not only inverters with Wi-Fi, mobile networks or Bluetooth, but also devices with Ethernet or similar wired connections. According to the definition, it is sufficient for a device to be designed, equipped or configured to incorporate a corresponding communication component.

In terms of product planning, this means that omitting a built-in Wi-Fi module is not automatically a viable option. The option to retrofit the system or the use of wired remote monitoring may also be relevant. Conversely, stand-alone inverters – which are not designed for parallel operation with the public grid – do not fall under this narrow definition of an inverter. The decisive factor is the technical design, not merely the description in the data sheet.

What is the significance of US production and Section 45X?

The revised regulation excludes inverters from the definition of „foreign-produced“ if they qualify for the Advanced Manufacturing Production Credit under Section 45X or meet the relevant requirements for a US domestic end product.

In the case of the latter approach, what matters is, in principle, whether the product is manufactured in the USA and whether the required US share of component costs is met. Mere final assembly in the USA is therefore not necessarily sufficient. Nor does the Section 45X provision constitute a general exemption for inverters manufactured in Germany.

Which robotic devices are on the Covered List?

The robotics entry relates to defined mobile robotic devices operating on the ground, such as autonomous transport robots, humanoid robots or four-legged platforms. Key requirements include operation based on commands or sensor data at a distance from an operator, and a total weight of more than 4.4 pounds – approximately two kilograms – including any ground or docking station that may be present.

Furthermore, the definition of environmental sensor technology requires a wired or wireless network connection with a speed of at least 200 kilobits per second in at least one direction, as well as software for the navigation, motion, perception, data acquisition or remote control functions it performs.

Stationary industrial robots, on the other hand, are expressly excluded. A permanently installed, non-mobile robotic arm therefore does not fall under this robotics entry solely on the basis of its connectivity. Other exceptions include, amongst other things, certain medical devices. A mobile production or logistics robot, on the other hand, must be assessed independently in accordance with the definition.

Why are German manufacturers also affected?

The new entries are not exclusively linked to specific companies or „critical“ countries of origin. Rather, the decisive factors are the location and circumstances of production, as well as the relevant requirements applicable to a US-manufactured product. A US company may therefore also be affected if it has its equipment manufactured outside the US.

For German companies, therefore, neither the fact that their head office is in Germany nor the political partnership between Germany and the US is sufficient. Nor does the existence of a US sales company, in itself, alter the classification of the equipment it distributes. The assessment must be carried out at product level.

Can products that have already been approved by the FCC still be sold?

In principle, yes. The inclusion of these product categories does not automatically revoke previously granted FCC authorisations. According to the FCC’s guidance, models authorised prior to this inclusion may continue to be imported, marketed, sold and used. This applies not only to devices that are already physically located in the US. However, other applicable restrictions must still be examined separately.

The key factor is whether the specific model and its configuration have been approved. This does not imply blanket grandfathering for all of a manufacturer’s future products. Product modifications must also be assessed on a case-by-case basis.

For certain software and firmware updates to devices that have already been approved, the FCC has created a limited exemption under DA 26-789, which, according to the published regulations, is valid until at least 1 January 2029. It does not constitute a general authorisation for new models or any hardware modifications.

Conditional Approval: How can manufacturers obtain an exemption?

A procedure for conditional approval is available for products covered by the scheme. This involves assessing whether a specific device or group of devices does not pose an unacceptable safety risk, despite its general classification.

Responsibility varies according to product category: in the case of inverters, the relevant safety decision may be taken by the US Department of Defence – referred to as the Department of War in the FCC documents – or by the Department of Homeland Security. For the robotic devices covered by the regulations, only the Department of Defence is designated as the competent authority.

A conditional approval does not replace the actual FCC device authorisation. Rather, it can remove the ‘Covered List’ restriction for the specific products listed, thereby enabling access to the standard authorisation procedure.

What documents are required?

The published guidelines require, in particular, details of the company’s and owners’ structure, components, supply chains, software and firmware, as well as a specific, time-bound plan for establishing or expanding production in the US. The US production plan should also cover investments, responsibilities and progress reports.

The process is therefore much more than just an additional technical certification. It may necessitate strategic decisions regarding procurement, manufacturing and investment.

What is the deadline?

According to the published procedural guidelines, applications must be submitted by 1 January 2028 at the latest. This deadline does not constitute a transitional period for the free distribution of new products. Submission alone does not override the existing restrictions and does not guarantee approval.

Have any exemptions already been granted?

Yes. On 9 September 2026, the FCC published Conditional Approvals for certain routers and robotic devices under DA 26-957. These include four specifically named Husqvarna robotic mower platforms. Husqvarna confirmed the decision on 11 September 2026. The case demonstrates that the exemption procedure is being utilised in practice; however, it does not imply a general exemption for European manufacturers.

What German companies should be looking into now

For implementation, it is recommended that a joint review be carried out by the product development, procurement, sales and US legal teams.

Compare the product portfolio and regulatory status. For each relevant US model, documentation should be kept detailing its technical specifications, where it is manufactured and which FCC approvals have already been obtained. New models, ongoing approval procedures and planned changes should be dealt with separately from existing models that continue to be sold without modification.

Assess the economic viability of alternative routes. Before preparing an application or deciding to relocate production, it should be clarified whether the product falls within the scope of the relevant entry at all. Only then can a meaningful assessment be made as to whether a conditional approval, a different product configuration or an adjustment to the manufacturing process is the appropriate course of action.

Coordinate contracts and market launch. When entering into new US supply contracts, companies should clarify who is responsible for obtaining approvals, what evidence suppliers must provide, and how delays or failed approvals are to be handled. Delivery dates should not be based on the unchecked assumption that a product previously placed on the market will automatically be authorised in its next generation.

Frequently asked questions about the FCC Covered List

Does the regulation apply only to Chinese manufacturers?

No. The new entries are not limited to Chinese companies. German manufacturers and US companies with overseas production facilities may also be affected.

Is every industrial robot affected?

No. The entry relates to defined mobile robotic devices. Permanently installed, stationary and non-mobile industrial robots are expressly excluded.

Is it sufficient to do without wireless technology in an inverter?

Not necessarily. Wired communication, in particular Ethernet, and the design provision for incorporating the relevant communication components may also be covered.

Conclusion: Access to the US market begins before the application for authorisation

For German manufacturers, checking the FCC Covered List should already be part of their product and market launch planning. The key question is not only: „Does our device meet the technical FCC requirements?“, but also: „Is this specific model even permitted under the current Covered List rules?“

By collating technical classifications, production conditions, existing approvals and possible exemptions at an early stage, you can lay a more robust foundation for the next US product launch.

Legal notice

This article is intended solely for general information purposes and does not constitute legal advice. It refers to the date of publication stated. Regulatory requirements, official interpretations and exemptions may change at short notice; we cannot guarantee that this article will be kept up to date.

Whether a particular product is covered by the FCC Covered List, which authorisation requirements apply and whether an exemption may be applicable requires a case-by-case assessment of the technical characteristics, manufacturing conditions and existing authorisations. Companies should therefore not base business decisions solely on this article, but should seek qualified legal advice beforehand. The provision or reading of this article does not constitute a client-solicitor relationship.