Robots and the FCC Covered List: Checking Eligibility Before a Lease

What did the FCC add on July 28, 2026?

On July 28, 2026, the Federal Communications Commission added foreign-produced advanced robotic devices to its Covered List. Public Notice DA 26-786 carves out devices that have received a Conditional Approval from the Department of War (DoW). The entry restricts new FCC equipment authorizations, so it works as a gate on new models rather than a blanket ban on robots made abroad.

For most facilities the answer splits in two. Models authorized before July 28 can still be produced, marketed, imported and used in the United States unless the FCC takes further action, according to Wiley. A new model that never received authorization before that date generally cannot be sold in the US without Conditional Approval, according to Morgan Lewis.

Which robots fall inside the definition?

Morgan Lewis describes a covered device as a mechanical mobile device that can locomote or navigate and operates at a distance from a human operator. Fixed, stationary industrial or medical robots, including articulated, SCARA and gantry robots, fall outside it. K&L Gates adds a weight threshold of over 4.4 pounds and network connectivity, and notes that the FCC FAQ includes robot vacuums and robot lawn mowers when they meet the definition.

Mofo reads warehouses the same way: mobile warehouse robots that navigate autonomously are likely covered, while traditional arms bolted to a factory floor should not be. A plant running a palletizing cell next to an AMR fleet therefore has two different questions to answer.

Foreign-produced is a separate test. A device counts as foreign-produced if it is not a domestic end product under 48 CFR 25.101(a). Morgan Lewis summarizes the general test as domestic component costs above 65 percent for items delivered in calendar years 2024 through 2028. The bar rises later, and the sources disagree on the level: K&L Gates says 70 percent in 2029, while Steptoe says 75 percent.

What about robots already running in your building?

Authorization attaches to the model, not to the brand or the date a unit reached the shelf. Morgan Lewis warns that a product developed, manufactured or placed in inventory before July 28 should not be assumed to qualify if it never received the applicable FCC authorization. A unit sitting in a warehouse on July 27 carries the same open question as one that arrived in August.

Steptoe confirms that existing authorized devices can continue to be imported and sold. That protects a fleet only if each unit traces back to a real authorization record. Two units from the same manufacturer may not be the same question if one is an older model and the other is a later hardware revision.

How does the firmware waiver keep robots updated?

The Office of Engineering and Technology granted a limited waiver. Morgan Lewis reports that covered devices authorized before July 28, 2026 can keep receiving qualifying Class I and Class II software and firmware updates through at least January 1, 2029. Covered updates include vulnerability patches and operating-system compatibility updates.

The waiver covers software, not hardware. Wiley notes that hardware changes remain prohibited absent a separate waiver, so a sensor swap or a board change raises a new eligibility question even on an authorized model. The waiver is also not the route for new launches, which still depend on Conditional Approval.

How does a new model get Conditional Approval?

Only DoW can grant Conditional Approval for advanced robotic devices, according to Morgan Lewis. Applications go to conditional-approvals@fcc.gov no later than January 1, 2028, and must include a certification by an authorized corporate officer. Approvals are still moving: the FCC's October 16, 2026 notice, DA 26-1114, says DoW granted approval for certain devices and the Covered List is updated to exclude them.

The FCC Covered List page, dated October 21, 2026, showed these Conditional Approvals for robotic devices:

Entries change as DoW acts, so treat that snapshot as a starting point and check the live page before any quote depends on it.

• Vulcan Robotics Inc., Sourccey mobile robotic platform: October 21, 2026
• Volley Automation, Inc., AGV and AMR: October 16, 2026
• Matic Robots, Inc., Robotic Floor Cleaner Model 4MA0001 and Charging Dock Model 4DK0008: October 2, 2026
• ANSCER Robotics AR250, AR650 and AR1250: September 18, 2026
• Husqvarna AB 305v IQ, 310v IQ, 420v IQ and 440v IQ robotic platforms: September 9, 2026

How do you check a model before you commit?

Start with the exact model number, not the product family or the marketing name. Eligibility is decided at that level, and a family name can hide several hardware generations. Then work through the checks in this order.

Two details trip people up. A pending application is not an approval, and an approval only helps if the approved configuration matches the hardware you will actually receive. Get each answer in writing before a delivery date depends on it.

• Pull the model's FCC equipment authorization record and confirm the grant predates July 28, 2026 and covers the hardware being delivered.
• Search the Covered List page for the model name and read any Conditional Approval entry and its date.
• For any mobile device, confirm it meets the covered definition, then ask the vendor to document its domestic component share against the 65 percent test for 2024 through 2028 deliveries.
• Ask for the firmware support plan in writing and check it against the January 1, 2029 waiver date.
• For any new model, require proof of an issued Conditional Approval before signing, not a pending application.

Where does Service Robot Co. fit in this check?

Service Robot Co. is an OEM-neutral integrator. We pick robots across manufacturers, then finance, deploy, integrate, train and service every unit through a nationwide US engineer network. Our offer is a lease: a 3-year lease with one fixed payment quoted after a site assessment.

The eligibility check belongs before that payment is quoted. During site assessment we confirm each model in a plan against the steps above, and we flag any model whose status depends on a Conditional Approval that is still pending. A waiver keeps existing software current, but it is not a launch approval, so we do not treat it as one.