Pudu's ET1 Launch and FCC Model Dates: A Quote Checklist

Why does the model's FCC date matter before a quote?

On July 28, 2026, the FCC updated its Covered List to add foreign-produced advanced robotic devices, defined as mobile robots such as humanoids and quadrupeds. Pudu launched its ET1 scrubber-dryer on August 12, 2026. At the time of reporting, no waiver for the ET1 had been announced, which makes it a clear case study in why the date a specific model was authorized belongs on your quote checklist.

The short version for a quote: a model authorized before the cutoff is treated differently from one that arrived after it. Skadden reports that the action does not affect models already FCC-authorized, and those models may still be sold. A new foreign-produced model generally cannot get FCC authorization for import, marketing or sale without Conditional Approval, so the paperwork behind a model matters as much as its specifications.

What did the July 28 action actually cover?

The FCC fact sheet describes the category as mobile robots such as humanoids and quadrupeds. The operative definition reaches further than those two examples but stops short of every robot with wheels. Morgan Lewis reads it as covering ground robots over 4.4 pounds that carry a sensor, qualifying connectivity, and autonomous or remote-command software. Fixed industrial arms, including articulated, SCARA and Cartesian units, are excluded, along with uncrewed aircraft.

The IFR's August 7, 2026 analysis says the definition may encompass service robots, AMRs, humanoids, quadrupeds and certain consumer robotic devices. National Law Review reports that the FCC FAQ includes robot vacuums and robot lawn mowers when they meet the definition. A floor scrubber with autonomous navigation and remote-command software can therefore fall inside the rule, even though the category name never mentions cleaning.

Where a robot is assembled does not settle the question alone. Morgan Lewis notes that foreign-produced is defined by the Buy American standard, so the manufacturer's home country is not determinative. Check the model's authorization record, not the brand's reputation.

Why does the authorization date decide what you can sign for?

Skadden reports that the action does not affect models already FCC-authorized, and previously approved models may still be sold. That protection attaches to a specific model and its grant. It does not follow a brand name across a product line, so a newer model from the same manufacturer can land on the other side of the line.

Morgan Lewis reports that a new foreign-produced model generally cannot obtain authorization without Conditional Approval, and that applications are due by January 1, 2028. Skadden notes that Conditional Approval is available from the Department of War for robotic devices.

Morgan Lewis also reports a limited OET waiver for Class I and II software and firmware updates to models authorized before July 28, 2026, running through at least January 1, 2029. That keeps existing units maintained. It does not authorize a new model, so a quote that depends on a post-cutoff model is relying on something the waiver cannot provide.

What does the ET1 launch show?

Pudu released the ET1 on August 12, 2026, as the first product in its new PUDU E Series. According to the vendor's release, the machine is built for 100 to 800 square meters, including convenience stores, drugstores, chain restaurants, business and economy hotels and offices. These are vendor-reported claims. The same release lists a scrubbing roller up to 800 rpm, 85 degree Celsius hot scrubbing, and minimum clearances of 50 cm width and 60 cm height.

The launch came 15 days after the cutoff. TechTimes, reporting on August 13, 2026, says new models launched after July 28, including the ET1, need a conditional approval waiver before US sale, and that no waiver for the ET1 had been announced. It advises confirming status with Pudu's US distribution contacts. TechTimes calls the requirement a waiver, while the FCC documents describe Conditional Approval from the Department of War, so use the FCC wording in any contract.

The lesson is not that the ET1 is unsafe or unavailable. A product announcement tells you a model exists, while the FCC record tells you whether it can be sold and serviced in the US on the timeline a quote assumes. Those are two different documents, and only one of them belongs in your decision.

Which questions should you put to a provider before signing?

Ask for answers in writing, tied to a model number and hardware revision rather than a product family. KnoxLabs makes the useful point that TAA compliance is not an automatic FCC exemption, and advises checking the exact model, hardware revision, FCC ID and original grant date. Those four identifiers are the starting point for any approval check.

• The exact model name, hardware revision, FCC ID and original grant date.
• Whether that model was authorized before July 28, 2026, or is still awaiting Conditional Approval.
• For any pending model, the application status and the date the provider expects a decision.
• Which units in the provider's current US stock carry pre-cutoff grants.
• Whether the software update waiver covers the exact model and revision named on your quote.
• What happens to the fixed payment and the install schedule if a unit cannot ship on time.

How does a newly launched model create delivery risk?

Even a model that eventually gets approved can slip. A launch announcement starts one clock, and the authorization record runs on another. Review periods, application deadlines and the supply of pre-cutoff stock can all move independently of the product's marketing timeline.

Supply rules can also shift during review. Natlaw Review reports that the July 22, 2026 Third Report and Order closed the component part loophole for new applications, and that an accompanying proposal would cut the R&D import allowance for foreign-produced robots from 4,000 units to 40. That is a proposal, not a final rule, so treat it as a risk to watch rather than a settled change.

Build fallbacks into the quote. Name an alternate model that already holds a pre-cutoff grant, set a dated checkpoint for any pending approval, and put in writing what happens if the unit cannot arrive on schedule.

How Service Robot Co. checks approvals before a quote

We are a vendor neutral robot integrator. We compare models from several manufacturers against your floor, your cleaning or transport task, and the approval record before we put a number on a quote. The authorization question gets answered at the front of the process, not after a signature.

We lease robots only. A customer starts with a site assessment, then receives one fixed payment on a 3-year lease, with deployment, integration, training and service handled by our nationwide US engineer network under one partner and one number. The FCC record sits in that review next to floor mapping and route planning, and a fixed payment should never rest on a model whose status is still open.