Short-Circuited: FCC Updates Covered List to Prohibit Foreign Power Inverters and Advanced Robotic Devices

Background

On July 28, 2026, the Federal Communications Commission (FCC) updated its Covered List, established through the Secure and Trusted Communications Networks Act to include foreign-produced connected power inverters and advanced robotic devices. The designation of these products to the Covered List follows an Executive Branch national security determination that they “pose unacceptable risks to the national security of the United States or the safety and security of United States persons.”

Equipment listed on the Covered List is ineligible for FCC equipment authorization, effectively prohibiting the import, sale, or marketing of those products absent an exception or approval.

This action comes only months after the FCC added consumer-grade routers to the Covered List on March 23, 2026 and uncrewed aircraft systems (UAS) on December 22, 2025. Taken together, these actions reflect the FCC’s increasingly expansive approach to using its authorities to guard against foreign produced connected technologies that may create vulnerabilities enabling disruption of critical infrastructure, unauthorized access to sensitive information, or cyber intrusions. The shift is a departure from the FCC’s previous focus on equipment and services produced by certain PRC and Russian companies.

Connected Power Inverters and Advanced Robotic Devices

The FCC’s recent action adds two new categories of products to the Covered List: foreign produced connected power inverters and advanced robotic devices. A connected power inverter or an advanced robotic device is considered "foreign" if it does not qualify as a “domestic end product,” as that term is defined under the Buy American rules at 48 CFR § 25.101(a).

Advanced Robotic Devices: As part of the national security determination underlying the designation of “advanced robotic devices” to the Covered List, the FCC cited concerns that increasingly autonomous and network-connected robots may collect sensitive data, facilitate foreign intelligence collection, or be vulnerable to remote manipulation.

As defined, “advanced robotic devices” include any “mechanical device, including autonomous mobile robots, humanoid robots, and quadrupeds” that meet four requirements: (1) it is capable of location, obstacle avoidance, navigation, or movement on the ground; (2) operates at a distance from a human operator or supervisor based on commands or in response to sensor data or any combination thereof; (3) the combined weight of the device and ground/docking station is over 4.4 lbs; and (4) contains three types of components (i.e., sensor, component providing network connectivity, and software controlling the autonomous navigation, data collection, or remote command and control).”

Certain connected vehicles (subject to the ICTS Supply Chain: Connected Vehicles Rule), industrial robotic arms, medical robots, vehicles, drones, and other excluded systems are outside the scope of the designation.

Connected Power Inverters: The national security determination also found that foreign-produced connected power inverters present significant risks because they can provide remote access into critical energy infrastructure and may be exploited to disrupt electric systems or facilitate cyber operations affecting the U.S. power grid. The designation is intended to reduce supply chain vulnerabilities associated with increasingly connected energy infrastructure.

The FCC defines connected power inverters as: “(a) 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 (b) contains components that enable remote communication, control, sensing, data collection, or monitoring through Wi-Fi, cellular, Bluetooth, or other similar connections.”

Exceptions

The practical effect of the designation is that new models of these products cannot be imported, marketed, or sold in the United States absent a conditional approval, which can be obtained by submitting an application to the FCC. Those applications are then reviewed by the Departments of War and Homeland Security.  While DoW can review all applications for conditional approvals, DHS can only grant approvals for power inverters. The FCC describes the application process, which includes an explanation of the company’s manufacturing process and supply chains, in an annex to its notice. FCC’s Notice “Foreign-Produced Advanced Robotic Devices” and “Foreign-Produced Power Inverters” Unlike Conditional Approvals for consumer grade routers, these approvals are indefinite.

Looking Ahead

The FCC’s action demonstrates that the agency continues to expand its use of equipment authorization restrictions as a national security tool to mitigate potential supply chain vulnerabilities and incentivize onshore U.S.-based manufacturing.

Companies operating in sectors involving connected infrastructure, industrial automation, robotics, energy systems, or internet-enabled devices should anticipate continued regulatory scrutiny as the FCC adds to its Covered List even if those products are designed or manufactured in U.S. allied countries. Companies should consider whether their products are affected by the FCC’s actions, including:

• identifying products that may fall under the definitions of “connected power inverters” or “advanced robotic devices” newly designated to the Covered List;
• reviewing manufacturing locations and supply chains for those products potentially affected by the new designations;
• evaluating pending or future FCC equipment authorization applications;
• assessing current and future contractual commitments involving covered technologies;
• considering alternative sourcing or manufacturing options where appropriate; 
• monitoring future FCC guidance regarding implementation, exemptions, or conditional approval procedures