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

On July 28, 2026, the Federal Communications Commission (“Commission”) took action to add foreign-produced power inverters and advanced robotic devices to its “Covered List.” The move closely mirrors other recent Covered List actions by the Commission, which added foreign-produced uncrewed aircraft systems (“UAS”) and UAS critical components to the Covered List in December 2025, as well as foreign-produced routers in March 2026.

Items on the Covered List are prohibited from receiving equipment authorizations from the Commission, and thus generally cannot be imported, marketed, or sold in the United States. In both instances, exemptions are available for products that have received “Conditional Approvals” from the Department of War (“DoW”) in the case of advanced robotic devices, or from DoW or the Department of Homeland Security (“DHS”) in the case of power inverters, as further described below. The approval process for UAS, UAS critical components, and routers involve both DoW and DHS.

Background

With respect to both power inverters and advanced robotic devices, the term “foreign-produced” means any article that would not qualify as a “domestic end product” under the regulations of the Buy American statute, as described at 48 C.F.R. § 25.101(a).

Power inverters are devices used to convert direct current electricity into alternating current electricity and vice versa. For purposes of the Covered List, a “power inverter” is specifically defined as:

A bi-directional power device or system that converts direct current electricity to alternating current electricity, or converts alternating current electricity to direct current electricity, to include microinverters, string inverters, central inverters, and hybrid (battery-based) inverters; and
Contains components that enable remote communication, control, sensing, data-collection, or monitoring through Wi-Fi, cellular, Bluetooth, or other similar connections.

Advanced robotic devices subject to this new determination include unmanned ground vehicles, quadrupeds, and other devices with use cases in monitoring and securing critical infrastructure. Specifically, these devices are defined as:

A mechanical mobile device, including autonomous mobile robots, humanoid robots, and quadrupeds, that:

Is capable of locomotion, obstacle avoidance, navigation, or movement on the ground;
Operates at a distance from a human operator or supervisor based on commands or in response to sensor data or any combination thereof; and
The combined weight of the device and, if applicable, ground station or docking station is over 4.4lbs; and
Contains a component falling within each of the below subparagraphs:

a sensor capable of perceiving its environment;
a component that is capable of providing network connectivity (wired or wireless, including Bluetooth/WiFi, cellular, or satellite) with connection speeds of at least 200 kbps in either direction; and
software running either locally or remotely, including firmware and AI or machine-learning model weights, that controls the robot’s autonomous navigation or movement perception, data collection, or remote command-and-control; and

Does not include:

A “connected vehicle,” as that term is defined in 15 CFR § 791.301, but including a connected vehicle of any gross weight;
A vehicle operated only on a rail line;
An “uncrewed aircraft” or “uncrewed aircraft system,” as defined in 47 CFR § 7 88.5;
An unmanned underwater vehicle that is able to operate without a human occupant;
Items that are classified as devices under section 513 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. §360c), including surgical instruments, components, and ambulatory and mobility assistive devices (such as canes, crutches, walkers, and wheelchairs), whether or not powered, and whether the item was cleared under section 510(k), approved under section 515, classified under section 513(f)(2), or exempt from premarket notification; and
A fixed, stationary, non-mobile robot, including articulating, parallel/delta, Cartesian/gantry, or Selective Compliance Assembly, or Articulated, Robot Arm (“SCARA”) robots intended for industrial or medical use.

National Security Rationale

The Covered List additions of both power inverters and advanced robotic devices follows National Security Determinations by an Executive Branch interagency body, which described the national security risks posed by both categories of devices. With respect to power inverters, the interagency group noted the potential risks from foreign-produced devices to critical infrastructure security:

The lack of a secure US supply chain for inverters and the continuous inflow of foreign-produced or controlled inverters and inverter components poses threats to US economic and national security . . . Inverters’ remote connectivity introduces additional vulnerabilities which compound as inverter-based resources proliferate on the US grid. These vulnerabilities could enable foreign firms to turn off the inverters or use them to collect and exfiltrate data, facilitate remote access and surveillance by foreign government actors, or be otherwise exploited through a cyberattack.

The group noted similar risks from foreign-produced advanced robotic devices, stating:

The networked capabilities of advanced robotic systems create extensive vulnerabilities and vectors for attacks that can manipulate the data and physical operation of the advanced robotic system. Relying on foreign-produced advanced robotic devices presents unacceptable supply chain and cybersecurity vulnerabilities . . . Advanced robotic devices collect data that could be leveraged by malign actors to surveil Americans, enhance the capabilities of foreign intelligence services, or to remotely commandeer the robots.

Conditional Approvals

As noted, producers of covered advanced robotic devices may apply for Conditional Approvals from the DoW, and producers of covered power inverters may apply for such approvals from DoW or DHS. In both instances, products that received Conditional Approvals are exempted from the Covered List, and thus the associated equipment authorization restrictions do not apply.

The process for Conditional Approval applications appears to closely echo similar processes for foreign-produced UAS, UAS critical components, and routers. Applicants will need to provide:

Detailed information on ownership structure, beneficial ownership, board membership, and foreign government ownership, control, influence, financing, or material support;
Manufacturing and supply chain information, including bills of materials, country of origin information for components, details on intellectual property ownership and supply chain information; and
A detailed, time-bound plan to establish or expand manufacturing in the United States, including a description of committed and planned capital expenditures, financing, or other investments dedicated to US-based manufacturing and assembly over the next 1-5 years, with timelines and milestones.

Conclusion

The Commission’s Covered List actions will have far-reaching effects across industries that rely on foreign-produced power inverters or advanced robotic devices. Interested parties should carefully assess the impacts and evaluate the feasibility of submitting an application for Conditional Approval. Mayer Brown attorneys have experience with this process and are available to assist.