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For robot makers · Compliance

FCC Covered List and robots: what it means for robot makers choosing Canada vs the US

· Updated · 8 min read

Short answer: On July 28, 2026 the FCC added "foreign-produced advanced robotic devices" to its Covered List (Public Notice DA 26-786). New robot models in scope can no longer receive FCC equipment authorization, which in practice keeps them out of the US market, with narrow exceptions (limited imports for testing, re-export, sales to the US federal government). Robot models the FCC authorized before July 28 are not subject to the new-model ban and can still be imported, sold and used, though changes to them are restricted. The main way back in for new models is a Conditional Approval from the Department of War (DoW), tied to a plan to manufacture in the US. Canada runs its own, separate radio certification through ISED, and as of October 11, 2026 we found no Canadian measure similar to the FCC's.

This is a summary of the FCC's public documents, not legal advice. Whether a specific robot is in scope is a question for a US lawyer and your test lab. KeepRobots is a robot field service company; we do not provide legal or certification services.

The rule at a glance

QuestionWhat the FCC documents say
EffectiveJuly 28, 2026 (DA 26-786, Public Safety and Homeland Security Bureau)
BasisNational Security Determination dated July 27, 2026, by an Executive Branch interagency body convened by the White House
CoveredGround-mobile "advanced robotic devices", explicitly including autonomous mobile robots, humanoid robots and quadrupeds
ExcludedFixed industrial/medical robot arms, drones (listed separately), connected vehicles, rail-only vehicles, unmanned underwater vehicles, FD&C Act medical devices
"Foreign-produced"Any article that is not a "domestic end product" under 48 CFR 25.101(a). Based on place of production; country neutral
New modelsCannot receive FCC equipment authorization
Previously authorized modelsImport, sale and use not prohibited; changes restricted
Software/firmware updatesWaiver for updates that mitigate harm to US consumers on devices authorized before July 28, 2026, at least until January 1, 2029 (DA 26-789)
ExceptionConditional Approval by the Department of War, based on a US onshoring plan

Which robots are covered?

Appendix C of the notice defines an advanced robotic device as a mechanical mobile device, "including autonomous mobile robots, humanoid robots, and quadrupeds", that:

  1. is capable of locomotion, obstacle avoidance, navigation or movement on the ground;
  2. operates at a distance from a human operator, based on commands, sensor data or both;
  3. weighs over 4.4 lb together with its ground station or docking station, if it has one; and
  4. contains all three of: a sensor that perceives its environment; a network connection (wired or wireless, including Bluetooth, Wi-Fi, cellular or satellite) of at least 200 kbps in either direction; and software, running locally or remotely, that controls autonomous navigation or movement, perception, data collection or remote command-and-control. The definition says this software includes firmware and AI or machine-learning model weights.

The FCC's FAQ adds that AGVs on fixed routes "may fall within" the definition, that robots working both under and above water (such as pool cleaners) are not excluded, and that a bare mechanical platform with no sensors, compute or RF parts is not covered.

That likely covers most commercial service robots: delivery and hospitality robots, commercial floor-cleaning robots, warehouse AMRs, inspection and security robots, humanoids and robot dogs.

Excluded: fixed, stationary robots (articulated, parallel/delta, Cartesian/gantry, SCARA) for industrial or medical use; drones; connected vehicles; rail-only vehicles; unmanned underwater vehicles; and devices regulated as medical devices, including surgical robots, prostheses and mobility aids.

Three points people get wrong:

  • It is not a China-only rule. The FCC's FAQ says the action "is country neutral" and the producer's nationality is not relevant. A robot built in Canada, Europe or Japan is foreign-produced too, unless it qualifies as a US domestic end product, and Canadian or other allied components do not count as domestic content.
  • The 4.4 lb threshold includes the dock. It is not a "2 kg robot body" test.
  • Mobile manipulators are not addressed separately. An arm on a mobile base looks like it falls under the mobile-device definition, but ask your lawyer about your specific product.

What still works

Robots you already sell in the US. The FCC fact sheet says the action "does not prohibit the import, sale, or use of any existing models" the FCC previously authorized, and that "the restrictions imposed today apply to new device models." Published legal analyses note that models still pending on July 28 are not protected, even if units are already in a warehouse.

Software updates. DA 26-789 waives the prohibition on permissive changes for software and firmware updates that mitigate harm to US consumers, on devices authorized before July 28, 2026, at least until January 1, 2029. Hardware changes are not part of that waiver, so check with your lab before swapping a radio module. The FAQ is explicit, though, that repairs of already-authorized devices and replacement of parts with identical parts are not prohibited.

Hardware maintenance beyond identical parts: a case-by-case waiver. On October 22, 2026 the FCC's Office of Engineering and Technology granted Intel a one-year waiver (DA 26-1146) of 47 CFR 2.932 and 2.1043, so Intel can make hardware, software and firmware changes to specific automated guided vehicles in its US semiconductor plants. The relief is narrow: only the AGVs listed in Intel's petition, kept in Intel's own facilities and not marketed, and Intel represented that the changes will not improve RF characteristics, alter functionality or replace a US-made component with a foreign one. It shows that the owner of a production-critical fleet can ask for maintenance relief beyond identical-part repair, but the waiver applies only to the petitioner. If your US customers will need non-identical replacement parts (for example when an original part is discontinued), have them and their US counsel look at this early.

New equipment authorization rules in force since October 13, 2026 (91 FR 57798). The FCC's Third Report and Order (FCC 26-50, ET Docket No. 21-232, published in the Federal Register on September 11, 2026 as 91 FR 57798) took effect on October 13, 2026. Four parts matter for robot service and spare parts:

  • Component rule (new 47 CFR 2.903(b)(2)). Equipment containing a logic-bearing hardware component produced by a Covered List entity, where that entity's own equipment would be prohibited, cannot be authorized. The FCC says this applies prospectively to new applications and does not affect previously authorized equipment.
  • Modifications that need a new certification (2.932(a), new 2.932(f), 2.1043(a)). Changes made by Covered List entities, or changes that would make the modified device covered equipment, cannot go through the permissive change process and need a new grant of certification.
  • How it applies to robots. The FCC says the rule on changes by Covered List entities does not apply to production-location-based entries, which is how the robot entry is written. It also says the prohibition reaches changes such as a shift in production to a Covered List entity or a change that would cause a device to lose domestic end product status (48 CFR 25.101(a): made in the US, with domestic components above 60% of cost, 65% for 2024–2028 deliveries and 75% from 2029).
  • FCC ID in online listings (47 CFR 2.803(c)). Online marketplaces must show the FCC ID at the point of sale: from March 1, 2027 for marketplaces with physical access to or title over the device, and from June 1, 2027 for those relying on third-party seller information.

Our reading (not the rule text, not legal advice): for foreign-produced robots already authorized and installed in the US, the rule does not close the identical-part repair path, but it makes sticking to identical parts more important. A non-identical replacement, especially a part made by a Covered List entity, could require a new certification that the robot entry would then block. Stock identical part numbers in North America, log every swap, never substitute parts from Covered List entities, and if your robot is US-made, check that imported replacement parts don't push it below the domestic end product threshold.

Conditional Approval. Robot makers can apply to the Department of War for Conditional Approval (submissions go to conditional-approvals@fcc.gov). The approval lets a producer keep receiving FCC authorizations while it moves manufacturing to the US. The Conditional Approval guidance attached to the determination (Annex A) sets an application deadline of January 1, 2028, as reported by several law firms. As of November 6, 2026, the FCC has announced 15 robot Conditional Approvals: Husqvarna AB's 305v IQ, 310v IQ, 420v IQ and 440v IQ robotic platforms (DA 26-957, September 9, 2026), ANSCER Robotics' AR250, AR650 and AR1250 robotic platforms (DA 26-996, September 18, 2026), Matic Robots' Robotic Floor Cleaner Model 4MA0001 with Charging Dock Model 4DK0008 (DA 26-1063, October 2, 2026), Volley Automation's AGVs/AMRs (DA 26-1114, October 16, 2026; no models listed), Vulcan Robotics' Sourccey mobile robotic platform (DA 26-1130, October 21, 2026), plus Haystack Robotics' Violet AI robotic device and T-Robotics' entire product class of automated guided vehicles (AGVs) (DA 26-1154, October 23, 2026); six more followed on October 30: ARAPL RaaS's autonomous pallet trucks and counterbalance forklifts, ATI Motors' Sherpa and FlexFork robotic platforms, Lightberry's Lumi interactive mobile robots, SunScout robotic platforms, Swap Robotics Canada's V7 robot, and OMRON's LD-150 and LD-300 robotic platforms (DA 26-1181, October 30, 2026); two more followed on November 6: ABB Robotics' AMMR G0540 and AMMR G1240 autonomous mobile manipulators and P204V autonomous mobile robot, and Pantograph's Pandroid robot hardware (DA 26-1203, November 6, 2026). All 15 are listed in the FCC's list of approvals (the appendix to DA 26-1203, updated November 6); we checked FCC notices through November 7 and found no newer robot approval. None of the 15 is a quadruped; the only humanoid is Lightberry's Lumi, which the company calls the first humanoid robot to be approved. According to Lightberry, Lumi is built on a G1 base (compatible with the Unitree G1); the company replaced the sensors, onboard computer and all software, and is starting US manufacturing with the body, head and hands. One of the six, Swap Robotics Canada Inc., is a Canadian company: the Covered List goes by where a device is produced, not who owns the company, so a Canadian company's robot made outside the US needs the same approval. These approvals have no fixed end date but depend on the company following its onshoring plan and passing updated vetting.

For every approval so far (company, models, date and notice) and what the application has to contain, see the FCC Covered List robot Conditional Approvals tracker.

US production. A robot that qualifies as a domestic end product is not foreign-produced. The FCC's FAQ uses the federal procurement thresholds: made in the US, with domestic components above 65% of component cost for items delivered 2024–2028, and 75% from 2029.

One caution: the FCC created a procedure in 2025 (FCC 25-71) to limit previously granted authorizations of covered equipment, and has already proposed using it against some previously authorized foreign drones. As of October 11, 2026 nothing similar has been proposed for robots. Worth watching.

Canada vs the US for a robot maker

United StatesCanada
Radio certificationFCCISED (separate system; foreign applicants need a Canadian representative under RSP-100)
New foreign-produced robot modelsBlocked unless Conditional Approval or domestic end productNo equivalent measure found as of 2026-10-11
Previously authorized modelsStill allowedNormal ISED rules apply
Electrical safetyNRTL-listed marks commonly required (e.g. UL, ETL)Canadian-accepted marks (e.g. CSA, cUL, cETL)
Market sizeMuch largerSmaller, but reachable now

For the product-safety side (UL 3300, UL 3100, CSA/cUL marks and OSHA NRTL listing), see UL 3300 for service robots: a plain-English guide.

What this means in practice:

  • Canada is not a back door into the US. An ISED certificate does nothing for FCC status, and a robot made in Canada is still foreign-produced under the US rule.
  • Canada can be where a new model meets North American customers first. If a new model cannot get FCC authorization yet, it can still go through ISED and Canadian electrical safety certification and be sold, deployed and supported in Canada. We cover the Canadian requirements in robot certification in Canada: CSA/cUL, ISED and UL 3300 (Chinese: 服务机器人进加拿大要哪些认证).
  • Your installed US fleet matters more now. Robots already in US buildings will need years of service, and there may be no new model to swap in when one fails. Repairs and identical-part replacements remain allowed. Keeping them running is a commercial priority, not just a support cost.

Deciding which country to launch in first (market size, duties, time zones, service base and whether Canada can be your reference site)? See US or Canada first? Where robot companies should launch in North America.

Questions to ask your lawyer and test lab

  • Does our product meet every part of the Appendix C definition, including the 4.4 lb (with dock) and 200 kbps tests?
  • Were all our US models fully authorized before July 28, 2026? Which variants were not?
  • Which planned changes are software-only (covered by the DA 26-789 waiver) and which need a hardware permissive change?
  • Can we prepare a credible onshoring plan and file a Conditional Approval application before January 1, 2028?
  • What happens to our US channel partners' stock and contracts if we cannot launch the next model?

What KeepRobots can do

We are a robot field service company based in Greater Vancouver, serving Canada and the United States. We do not do legal or certification work. What we can do under the new rule:

  • Keep your installed North American robot fleet running: hourly on-site robot repair, preventive maintenance and spare-parts storage, so already-authorized models stay in service longer.
  • Support a Canadian launch: robot deployment and commissioning, on-site pre-sales demos, staff training and acceptance.
  • English and Chinese; our engineers can read Chinese technical documents and work with your home team's hours.

See North America field service for robot makers and third-party robot service for robot manufacturers for how we work with manufacturers, or write to partners@keeprobots.com. Background on the service models: How robot makers can offer on-site robot service without hiring a team.

FAQ

Which robots are on the FCC Covered List?

Foreign-produced ground-mobile robots, explicitly including autonomous mobile robots, humanoids and quadrupeds, that weigh over 4.4 lb with their dock and have an environmental sensor, a network connection of at least 200 kbps and control software. Fixed industrial or medical robot arms, drones, connected vehicles and medical devices are excluded.

Can I still sell robot models that already have FCC authorization?

Yes. The FCC says the action does not prohibit the import, sale or use of previously authorized models; the restrictions apply to new models. Software and firmware updates that mitigate harm to US consumers remain allowed under an FCC waiver, at least until January 1, 2029, for models authorized before July 28. Repairs and identical-part replacements are not prohibited.

Does the rule only apply to robots made in China?

No. It applies by place of production. Any robot that is not a US "domestic end product" is foreign-produced, including robots made in Canada or Europe.

Can a new robot model still enter the US?

Through a Conditional Approval from the Department of War, which requires a US onshoring plan (applications due by January 1, 2028 under the Annex A guidance), or by manufacturing in the US as a domestic end product. Ask a US lawyer which fits your product.

What changed for robot repairs in the US with the FCC rules effective October 13, 2026 (91 FR 57798)?

Previously authorized robots are not affected by the new component rule (47 CFR 2.903(b)(2)), which applies only to new authorization applications, and repairs with identical parts remain allowed. The new rules require a new certification for changes made by Covered List entities or changes that would make a device covered equipment (2.932, 2.1043); the FCC says this includes changes that cause a device to lose domestic end product status. Keep replacements to identical part numbers, avoid parts from Covered List entities, and check non-identical swaps with your test lab or US counsel.

Has Canada adopted a similar restriction on robots?

As of October 11, 2026 we found no Canadian measure similar to the FCC's. Canada certifies radio equipment through ISED, a separate system, and the FCC Covered List has no legal effect there.

Sources (checked 2026-10-11)

This article summarizes public documents and is not legal advice. Whether a specific product is covered, or can obtain Conditional Approval, depends on the FCC's text and your US counsel's advice.

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