CES 2027 for robot companies: FCC display rules, ATA Carnet and post-show service planning
Short answer: CES 2027 runs January 6–9, 2027 in Las Vegas (per ces.tech). If you make robots outside the US, the first job is not booking the booth freight. It is checking each model's FCC status. Since July 28, 2026, new models of foreign-produced advanced robotic devices are on the FCC Covered List and cannot be authorized. The FCC's trade-show display rule only covers devices that could be authorized, and the FCC's robot FAQ has no trade-show exception. So: models authorized before the listing can be shown as usual; covered new models without a Conditional Approval should stay off the booth, powered or not. Second, an ATA Carnet handles duties and taxes, not FCC import conditions. Third, and most often skipped: buyers at the booth will ask "who fixes this in the US, and how fast?" Have the answer before you fly.
This guide is for robot makers (many of them in China) preparing for CES 2027: North America expansion leads, marketing and trade-show managers, and after-sales leads. The FCC part follows the eCFR text of 47 CFR 2.803, 2.805, 2.903 and 2.1204 and the FCC's Covered List FAQ for robots (updated October 27, 2026); the customs part follows US Customs and Border Protection's ATA Carnet FAQ. Checked November 12, 2026. "Our reading" marks interpretation. This is not legal, customs or certification advice: confirm each model with US counsel or your test lab. KeepRobots does not exhibit at CES and does not provide services at the show; this is a before-and-after checklist. For background on the rule itself, see the FCC Covered List and robots: Canada vs the US.
Step 1: sort your models into five groups
| Your model | Show or run it at CES? | Basis |
|---|---|---|
| Already FCC-authorized (has an FCC ID), including models authorized before July 28, 2026 | Yes, under the normal rules: import, display, operate, take orders | FCC FAQ: the listing does not affect continued import, marketing or sale of existing authorized models |
| Covered by a Department of War Conditional Approval (15 robot approvals as of 2026-11-06) | Can be authorized; before the grant, the normal pre-authorization rules apply (notice on display, unlicensed radios may be demonstrated and retrieved) | 47 CFR 2.803(d)(2), 2.805(d), 2.1204(a)(4) |
| A new model of a foreign-produced, ground-mobile robot in scope (AMR, humanoid, quadruped, delivery, cleaning) with no Conditional Approval | Do not display or operate it; confirm with US counsel or your lab before you ship | 2.903 bars authorization; the 2.803(d)(2) display exception only covers devices that could be authorized; FAQ: operating unauthorized covered robots in the US is generally "no" |
| Outside the robot definition: fixed industrial or medical robots (articulated, parallel/delta, Cartesian/gantry, SCARA), devices of 4.4 lb or less with their dock, medical devices | Not affected by the robot entry; normal FCC rules (radio module authorization, display notice) | DA 26-786, Appendix C definition and exclusions |
| Made in the US as a "domestic end product" | Not foreign-produced; normal rules | FCC FAQ, by reference to 48 CFR 25.101(a) |
Three calls that are easy to get wrong:
- A refresh is not the old model. A version with a different radio module, main board or enclosure may be a new model or need a new grant, and new grants are not available. Put the exact version that matches the FCC ID on the booth.
- An arm on a mobile base is judged as a whole. The exclusion is for fixed robots. Mobile manipulators are judged as complete devices; the Conditional Approval list already includes some.
- "Prototype. Not for Sale." is not a pass. 47 CFR 2.803(d)(2)(iii)(B) allows that wording only for a prototype of a device that has been authorized. Our reading: it does not get a covered robot's new variant onto a US booth.
Every approval so far (company, models, date, notice) is in the FCC Covered List robot Conditional Approvals tracker. As of 2026-11-06, none of the 15 is a quadruped, and the only humanoid is Lightberry's Lumi (per the company).
Step 2: the three FCC trade-show rules, and why they don't help covered new models
1. Display with a notice (47 CFR 2.803(d)(2)(iii)). A device that has not been authorized may be displayed at a trade show if accompanied by a conspicuous notice:
This device has not been authorized as required by the rules of the Federal Communications Commission. This device is not, and may not be, offered for sale or lease, or sold or leased, until authorization is obtained.
2. Operation before authorization (47 CFR 2.805(d)). Devices that operate only under Parts 15, 18 or 95 without a station license (Wi‑Fi, Bluetooth and similar) may be demonstrated at a trade show before authorization if the notice is displayed (or buyers are told in writing), the device complies with current technical rules, and it is retrieved or rendered inoperable afterwards. Cellular modules and licensed-band radios are not covered by this paragraph.
3. Import limit (47 CFR 2.1204(a)(4)). Unauthorized devices imported for trade-show demonstration are limited to 400 units per model and may not be sold or marketed. The ultimate consignee must be able to document which import condition applies (2.1204(b)).
Why none of this helps a covered new model: the 2.803(d)(2) exceptions apply only to devices that "could be authorized under the current rules," and those devices may not be operated unless 2.805 permits it. A covered new model cannot be authorized under 2.903, so it does not meet that condition. The FCC's robot FAQ is blunter: new foreign-produced advanced robotic devices "are generally prohibited from receiving FCC authorization to be imported, marketed, or sold in the U.S."; asked whether unauthorized covered robots can be operated in the US, it says "the general answer is 'no'"; new models may be imported only in small batches for product development or testing, not marketed or sold. The FAQ does not mention trade shows at all. Our reading: a booth is marketing, and a static display is still "displayed," so a covered new model should stay off a US booth even if it is never switched on.
What to do instead: put authorized models on the booth and present the new model by video and spec sheet. For prospects who need to see the real robot, consider a demo in Canada (as of our check we found no Canadian measure like the US robot entry; demo units follow ISED rules). A new model meant for the US market long term needs a Conditional Approval or US production; the tracker above lists what the application has to contain.
Step 3: getting the demo units in: the carnet covers duty, not the FCC
| Question | What CBP says | What it means for a robot maker |
|---|---|---|
| What the US accepts on a carnet | Commercial samples, professional equipment and certain advertising materials, temporarily imported by a nonresident | Exhibits go as commercial samples; booth tools and equipment as professional equipment. The exhibitions category does not apply in the US |
| Validity | One year from issue; goods may move in and out of carnet countries as often as needed; a replacement carnet can extend it, but not every country accepts one | After CES, a demo unit can move on to Canada on the same carnet within its validity; it has to be re-exported within the year |
| Selling | Goods intended for sale or sale on approval cannot use a carnet and need a regular entry; if carnet goods are sold, donated or disposed of, the guaranteeing association pays 110% of duties and taxes and recovers from the holder | You cannot sell the booth unit to a keen buyer; giveaways and other consumables cannot travel on a carnet |
| Other permits | CBP says an import or export license is required in conjunction with a carnet (per USCIB) | Our reading: FCC import conditions under 2.1204 still apply. A carnet does not make a covered new model importable |
| Without a carnet | Temporary Importation under Bond: file CBP Form 3461 or 7501, usually through a customs broker, with a bond from a licensed surety | For goods a carnet does not cover, or if you would rather not use one |
In China, ATA Carnets are issued and guaranteed by CCPIT (China Chamber of International Commerce). Robots with lithium batteries ship as Class 9 dangerous goods, and late bookings usually mean air freight; plan around that. Booth build, freight move-in and venue rules are set by the CES exhibitor manual.
Step 4: a working timeline, mid-November to four weeks after the show
| When | What |
|---|---|
| Mid-November (about 7 weeks out) | Fix the booth models: look up each FCC ID and grant date; replace covered new models with video. List demo units by serial number, with batteries and docks |
| Late November | Choose carnet or TIB and apply; appoint a US customs broker; book dangerous-goods freight |
| Early December | Ship. Prepare English booth material: FCC IDs, how North American after-sales works, pricing and lead times; notices for any unauthorized device |
| Mid to late December | Confirm arrival and clearance. Decide where each unit goes after the show: re-export, on to Canada as a resident demo unit, or a regular import |
| January 6–9 | Display, don't sell booth units. Log each lead's city, use case, fleet size and timing |
| Week 1 after | Send leads a pack: authorized models, who services them locally, response time, how service is charged |
| Weeks 2–4 after | Book on-site demos or pilots, authorized models only; put deployment, parts and support into the quote |
Timings are planning suggestions, not industry statistics. How to run the on-site demo that follows a show lead: running a pre-sales robot demo in North America without a local team.
Step 5: the after-sales questions every booth gets
CES brings distributors, retail buyers, property managers and enterprise buyers. Once they have seen what the robot does, the next questions are about what happens after the sale:
- "Who fixes it in the US, and how fast?" "Our HQ has remote support" is not an answer on its own. Say what remote support covers, who goes on site, which cities, and roughly how long it takes.
- "Where are the spare parts?" Stock in the US or Canada beats shipping from overseas. For authorized robots, the FCC FAQ says replacing parts with identical parts is not prohibited, so stock identical part numbers.
- "Will this model still be sold and serviced here?" Authorized models can keep being sold and repaired. Be straight about the status of anything new.
- "How long does deployment take, and who does it?" Hours and steps by robot type: robot deployment cost and timeline in North America.
Write these answers into the English booth material before the show. The options for US service without a local team are compared in nationwide robot service network or a dedicated field service partner; what you can still repair and replace on robots already sold in the US is in robots already sold in the US after the FCC Covered List.
Six things to do this month
- Make a booth model table: model, FCC ID, grant date, covered or not, Conditional Approval or not. Have US counsel or your lab confirm it.
- Prepare video and spec sheets for covered new models, and explain their status honestly at the booth.
- Settle customs and dangerous-goods shipping: carnet list matched to serial numbers, batteries listed separately.
- Decide where each demo unit goes after the show before you ship it.
- Write a one-page after-sales sheet in English: who goes on site, coverage, response time, how it is charged, where parts are.
- Follow up within two weeks: schedule demos and pilots by city, authorized models only.
What KeepRobots can do
KeepRobots is a robot field service company in Vancouver. We do not exhibit at CES and do not provide services at the show, and we do not give legal, customs or certification advice. Before and after the show we can:
- receive, unpack, store and regularly check your demo unit in Vancouver as a resident North American demo robot
- after the show, support your sales team at North American prospects' sites, or run the demo for you after a site survey
- once a customer buys, do on-site deployment, preventive maintenance and repair: Greater Vancouver first in Canada, and US sites on a per-project basis
- work in English and Chinese, read Chinese technical documents and overlap with factory hours
Rates, before tax: diagnostic US$200 in the US or C$200 in Canada per robot, per visit, credited when you approve the repair; on-site labour US$150 or C$150 per hour; C$100 call-out in the Greater Vancouver core zone; US travel and travel outside the core zone quoted per project. How US visits work: robot repair and field service in the USA. Or email partners@keeprobots.com with the model, where your post-show prospects are and your timeline. The full sequence of a North American launch: how to expand a robot company into North America.
FAQ
When and where is CES 2027?
January 6–9, 2027, in Las Vegas, per the organizer CTA at ces.tech. Booth, freight and venue rules are in the CES exhibitor manual.
Can an unauthorized new robot model be displayed at CES?
Not if it is a covered model. Since July 28, 2026, new models of foreign-produced advanced robotic devices (AMRs, humanoids, quadrupeds and other ground-mobile robots) cannot be authorized under 47 CFR 2.903. The 2.803 display exception only covers devices that could be authorized, and the FCC robot FAQ says unauthorized covered robots generally cannot be operated in the US and makes no trade-show exception. Confirm with US counsel or your lab; show the model by video, or arrange a live demo in Canada.
Can robots authorized before July 28, 2026 go to CES?
Yes. The FCC FAQ says the listing does not affect continued import, marketing or sale of existing authorized models. A refresh with a different radio module or main board may be a new model, so bring the version that matches the FCC ID.
Are robot arms affected?
Fixed industrial or medical robots (articulated, parallel/delta, Cartesian/gantry, SCARA) are excluded from the robot definition and follow the normal FCC rules. An arm on a mobile base is judged as a whole device.
Does an ATA Carnet solve the FCC problem?
No. A carnet guarantees duties and taxes. The US accepts commercial samples, professional equipment and certain advertising materials; it is valid one year; carnet goods cannot be sold, and if they are, the guaranteeing association pays 110% of duties and taxes. CBP says a carnet works in conjunction with any required licenses; our reading is that FCC import conditions under 47 CFR 2.1204 still apply.
A buyer wants to order, or buy the booth unit. What then?
The booth unit on a carnet cannot be sold; a sale needs a regular entry. Authorized models can be ordered normally. For devices that could be authorized but are not yet, 2.803 allows conditional sales contracts with prominent disclosures and no delivery to end users before the grant. That route is not open to covered new models, which cannot be authorized.
Will KeepRobots be at CES? What do you charge?
No. We do not exhibit at CES and do not provide services at the show. From Vancouver we can keep your resident demo unit, support or run post-show demos at North American sites, and handle deployment, maintenance and repair after the sale, in Greater Vancouver and on US sites per project. Rates before tax: diagnostic US$200 or C$200 per robot, per visit, credited when you approve the repair; labour US$150 or C$150 per hour; C$100 Greater Vancouver call-out; US travel quoted per project.
Sources
- CES 2027 (CTA): ces.tech; exhibitor manual: ces.tech/manual
- 47 CFR 2.803, marketing and display before authorization: ecfr.gov
- 47 CFR 2.805, operation before authorization: ecfr.gov
- 47 CFR 2.903, Covered List equipment barred from authorization: ecfr.gov
- 47 CFR 2.1204, import conditions: ecfr.gov
- FCC, Covered List FAQs on advanced robotic devices and power inverters (updated October 27, 2026): fcc.gov
- FCC Public Notice DA 26-786: docs.fcc.gov; Fact Sheet DOC-423682: docs.fcc.gov
- Latest Conditional Approvals notice: docs.fcc.gov
- CBP, ATA Carnet FAQs: cbp.gov; 19 CFR 10.31 (TIB): ecfr.gov
- People's Daily (customs Q&A on ATA Carnets in China, January 28, 2023): people.com.cn
A summary of public documents checked on November 12, 2026; Conditional Approval count as of 2026-11-06; "our reading" marks interpretation. Not legal, customs or certification advice: confirm with the FCC's own texts, US counsel, your test lab and your customs broker. KeepRobots does not exhibit at CES. Rates are current published rates, before tax, and may change.