FCC Covered List and Warehouse AMRs: What to Check First

Can a US warehouse keep running AMRs after the listing?

In most cases, yes. The FCC added foreign-produced advanced robotic devices to the Covered List on July 28, 2026, but according to the FCC fact sheet, the action does not prohibit the import, sale or use of models the FCC previously authorized. It does not affect devices already purchased.

The real pressure falls on new equipment. A warehouse that plans to add a foreign-produced AMR, or swap in a different model, has to confirm that the model sits outside the listing or holds a Conditional Approval. That check belongs in procurement, before a quote is signed and long before a robot reaches the dock.

Which AMRs fall inside the definition?

The FCC fact sheet defines advanced robotic devices as mobile robots, such as humanoids and quadrupeds. According to Morgan Lewis, a device meets the definition when it moves on the ground, operates at a distance from a human operator, weighs more than 4.4 pounds including any dock, carries a sensor, has network connectivity of at least 200 kbps, and runs control software locally or remotely.

IFR says the definition may encompass service robots, AMRs, humanoids, quadrupeds and certain consumer devices. Fixed industrial arms are explicitly excluded, including articulated, parallel, Cartesian or gantry, and SCARA designs. Most warehouse AMRs will meet the physical tests, so the practical questions are usually place of production and authorization status.

Why does place of production matter more than the brand?

Morgan Lewis notes that the listing is based on where a product is produced, not on the manufacturer's identity. A US headquartered company can still be affected when its product is not a domestic end product.

K&L Gates describes the domestic end product path as requiring US made components above 65 percent of device value today, rising to 70 percent in 2029. That is a threshold a vendor should be able to document, not a marketing phrase.

What does Conditional Approval actually grant?

For advanced robotic devices, only DoW can issue Conditional Approval, according to Morgan Lewis. FCC notice DA 26-996, released September 18, 2026, says DoW granted Conditional Approval to ANSCER Robotics' AR250, AR650 and AR1250 platforms, which are therefore exempt from the Covered List.

The approval is narrow. It applies to named platforms, not to a company or product family in general. The sources we reviewed show approvals for those three ANSCER models and for Husqvarna, a Swedish robotic lawn mower maker that Mondaq reports was approved on September 9, 2026. We found no approvals for other AMR makers in the sources we checked.

ANSCER describes its approval as transitional, tied to ongoing US manufacturing and reporting commitments, and distinct from a standard, unconditional FCC equipment authorization. Its release, which is vendor reported, also says other equipment authorization and product and deployment requirements remain separate. Read the approval as a set of conditions, not a clean bill of health.

How do software updates and deadlines fit in?

According to Morgan Lewis, the Office of Engineering and Technology granted a limited waiver allowing qualifying Class I and Class II software and firmware updates to previously authorized models through at least January 1, 2029. For a fleet, that means a model can stay in service while its controls are maintained, provided each update falls under the waiver.

Conditional Approval applications are due by January 1, 2028, per Morgan Lewis and Nemko. They must include corporate ownership, bill of materials, supply chain, software and firmware, and US manufacturing information. White & Case adds that the FCC would issue a separate public notice before any limits on previously authorized devices, and that step had not been triggered for the robot listing as of its writing. Existing models are not frozen out today, but the rules can still move.

What should you check in a model's status?

Start with the exact model, firmware version and any FCC notice that names it. Approvals attach to platforms, so a sibling model from the same maker can stand in a different position. Then review the items below with the vendor in writing.

• Whether the exact model is covered by an existing FCC authorization or by a named Conditional Approval, with the notice or grant number on file.
• Place of production and the documented share of US made components against the 65 percent threshold.
• Whether each planned software update falls within the OET waiver window through January 1, 2029, or needs a fresh review.
• Whether any Conditional Approval carries US manufacturing and reporting commitments, and whether the vendor is tracking them.
• Which party holds responsibility for equipment authorization and deployment requirements that the approval does not cover.

What should you ask a vendor before committing?

Put these questions to the vendor before any contract is signed. A clear answer takes minutes to give, and a vague one tells you something useful.

• Is this exact model and firmware version covered by an existing FCC authorization or a named Conditional Approval, and can you provide the notice or grant?
• Where is the robot produced, and what share of device value comes from US made components?
• Does the software roadmap stay inside the OET waiver window, and what happens to support after January 1, 2029?
• If a Conditional Approval is involved, what US manufacturing and reporting duties does the vendor carry, and what is the plan if those duties slip?
• If the model is later restricted, what replacement path, spare units and timeline does the vendor commit to in writing?

Where does an integrator fit this decision?

Eligibility is a lifecycle question, not a single check at purchase. Service Robot Co. is a vendor neutral robot integrator for US businesses. We compare robots across manufacturers, then deploy, integrate, train and service each unit through a nationwide US engineer network, so the same team that selects a model can follow its status when software changes.

We lease robots only, through financing on a lease term of 3 years, with one fixed payment quoted after a site assessment. Eligibility review belongs in that assessment, before a payment figure is set for your floor.