FCC Covered List 2026: Inverters and Robotics

As of September 18, 2026

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

However, this is not a blanket ban on all inverters and industrial robots. The key 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 August 20, 2026. Therefore, an assessment based solely on the original July announcement could lead to incorrect conclusions.

What is the FCC Covered List—and what are the implications of being included on it?

The FCC Covered List includes communications equipment and services that, according to the relevant U.S. security assessments, pose an unacceptable risk to national security or the safety of U.S. persons. Its legal basis is the Secure and Trusted Communications Networks Act of 2019. In particular, 47 CFR § 2.903(a) prohibits the issuance of an FCC equipment authorization for devices on the list.

The practical consequence: If a new product requires such approval, its inclusion on the Covered List can block its regular import and distribution in the U.S. The regulatory review therefore does not end with technical test reports. The question of whether the product may be approved at all also becomes a crucial part of the U.S. market launch.

The underlying security assessments cite, among other things, potential remote shutdowns, unauthorized access, data leaks, and dependence on foreign supply chains. In the case of inverters, the focus is particularly on the energy infrastructure; for networked robots, potential for surveillance and tampering are added concerns. These are the risks cited by U.S. authorities—not a determination that every affected product actually has a security vulnerability.

Which inverters are affected?

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

First, it must be an inverter that operates in parallel with the grid. The definition covers so-called utility-interactive inverters, as defined in UL 1741: devices that convert direct current to alternating current and are intended for parallel operation with the public power grid. Bidirectional devices may also fall under this definition.

Second, the device must have the appropriate communication capabilities or be equipped to support them. This covers not only inverters with Wi-Fi, cellular, or Bluetooth, but also devices with Ethernet or comparable wired connections. According to the definition, it is sufficient for a device to be designed, equipped, or configured to incorporate a corresponding communication component.

For product planning, this means that omitting a built-in Wi-Fi module is not automatically a viable solution. The ability to retrofit the system or the option for wired remote monitoring may also be relevant. Conversely, standalone inverters—which are not intended for parallel operation with the public grid—do not fall under this narrow definition of an inverter. The technical design is the determining factor, not merely the designation in the data sheet.

What is the significance of U.S. 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 U.S. domestic end product.

For the latter option, the key factors are, in principle, whether the product is manufactured in the United States and whether the required U.S. content of the component costs is met. Simply performing final assembly in the United States is therefore not necessarily sufficient. Nor does the Section 45X provision constitute a general exception for inverters manufactured in Germany.

Which robotic devices are on the Covered List?

The robotics entry applies to specific mobile robotic devices that operate 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, if present.

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

Stationary industrial robots, on the other hand, are expressly excluded. A fixed, non-mobile robotic arm therefore does not fall under this robotics entry solely because it is networked. Other exceptions include, among other things, certain medical devices. A mobile production or logistics robot, on the other hand, must be assessed independently based on the definition.

Why are German manufacturers also affected?

The new entries are not limited to specific companies or „critical“ countries of origin. Rather, the decisive factors are the location and circumstances of production, as well as the applicable requirements for a U.S. domestic product. Therefore, even a U.S. company may be affected if it has its equipment manufactured outside the United States.

For German companies, therefore, neither the fact that the company is headquartered in Germany nor the political partnership between Germany and the United States is sufficient. Even a U.S. sales subsidiary, in and of itself, does not alter the classification of the devices it distributes. The assessment must be conducted at the product level.

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

Basically, yes. The inclusion of these product categories does not automatically revoke previously granted FCC authorizations. According to the FCC’s guidance, models approved 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 United States. However, other applicable restrictions must still be reviewed 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 changes must also be evaluated on a case-by-case basis.

For certain software and firmware updates to devices that have already been approved, the FCC has established a limited exemption under DA 26-789, which, according to the published regulation, remains in effect at least until January 1, 2029. This is not a general authorization for new models or any hardware modifications.

Conditional Approval: How Can Manufacturers Obtain an Exemption?

A conditional approval process is available for products covered by the regulation. This process assesses whether a specific device or group of devices poses an unacceptable safety risk, despite its general classification.

Jurisdiction varies by product category: For inverters, the relevant safety decision may be made by the U.S. Department of Defense—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 regulation, the Department of Defense is the sole authority.

A conditional approval does not replace the actual FCC device certification. Rather, it can remove the "Covered List" restriction for the specific products listed, thereby allowing access to the regular approval process.

What documents are required?

The published guidelines specifically require information on corporate and ownership structure, components, supply chains, software, and firmware, as well as a concrete, time-bound plan for establishing or expanding production in the United States. The U.S. production plan should also cover investments, responsibilities, and progress reports.

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

What is the deadline?

According to the published procedural guidelines, applications must be submitted no later than January 1, 2028. This deadline is not a transition period for the free distribution of new products. Submission alone does not override existing restrictions and does not guarantee approval.

Have any exemptions already been granted?

Yes. On September 9, 2026, the FCC issued Conditional Approvals for certain routers and robotic devices in DA 26-957. These include four specifically named Husqvarna robotic mower platforms. Husqvarna confirmed the decision on September 11, 2026. The case demonstrates that the exemption procedure is being used in practice; however, a general exemption for European manufacturers cannot be inferred from this.

What German Companies Should Be Reviewing Now

For implementation, we recommend a joint review by product development, purchasing, sales, and U.S. legal counsel.

Compare the product portfolio and regulatory status. For each relevant U.S. model, documentation should be maintained detailing its technical specifications, where it is manufactured, and which FCC certifications have already been obtained. New models, ongoing certification processes, and planned changes should be handled separately from existing models that continue to be sold without modification.

Conduct an economic analysis of alternative routes. Before preparing an application or deciding to relocate production, it should be determined whether the product falls under 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 U.S. supply contracts, companies should clarify who is responsible for obtaining approvals, what documentation suppliers must provide, and how delays or failed approvals will be handled. Delivery dates should not be based on the unchecked assumption that a product previously marketed will automatically be approved in its next generation.

Frequently Asked Questions About the FCC Covered List

Does this regulation apply only to Chinese manufacturers?

No. The new entries are not limited to Chinese companies. German manufacturers and U.S. companies with overseas manufacturing operations may also be affected.

Are all industrial robots affected?

No. The entry applies 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, particularly Ethernet, and the design-intended inclusion of corresponding communication components may also be covered.

Conclusion: Access to the U.S. market begins before the marketing authorization application

For German manufacturers, reviewing 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 FCC’s technical requirements?“ but also, „Is this specific model even eligible for approval under the current Covered List rules?“

Those who consolidate technical classifications, production conditions, existing approvals, and potential exemptions early on will create a more robust foundation for the next U.S. product launch.

Legal Notice

This article is intended solely for general informational purposes and does not constitute legal advice. It reflects the information available at the time of publication. Regulatory requirements, official interpretations, and exemptions are subject to change at short notice; we cannot guarantee that this article will be updated on an ongoing basis.

Whether a specific product is included on the FCC Covered List, what approval requirements apply, and whether an exemption may be granted requires a case-by-case review of the product’s technical characteristics, manufacturing conditions, and existing approvals. Companies should therefore not base business decisions solely on this article but should first seek qualified legal advice. The provision or reading of this article does not create an attorney-client relationship.