Robots already sold in the US after the FCC Covered List: repairs, spare parts and software updates

Short answer: yes, you can repair them, replace parts with identical parts and push software and firmware updates that keep them working. What you can no longer do is change the hardware. Since the FCC added foreign-produced advanced robotic devices to the Covered List on July 28, 2026 (DA 26-786), new robot models cannot get FCC equipment authorization. Models authorized before July 28 can still be imported, sold and used. The FCC's robot FAQ says the Covered List rules do not prohibit repairs of already-authorized devices or the replacement of component parts with identical parts. Software and firmware updates have their own waiver (DA 26-789), at least until January 1, 2029. The catch is that covered equipment is shut out of the permissive change process, so substitute parts, a different radio module or a design change are effectively blocked.

For a robot fleet already working in the US, after-sales now comes down to two disciplines: replace only with the original part number, and be able to show that each software release is a maintenance update. With new models locked out, the installed base has to last longer, which makes local repair and spare parts more valuable than before.

This is written for robot makers, especially Chinese companies, with robots already installed at US customer sites. It follows the FCC's notice, fact sheet, waiver, FAQ and the text of 47 CFR, checked on November 7, 2026. Anything marked "our reading" is interpretation, not rule text. This is not legal or certification advice: confirm your product with a Telecommunication Certification Body (TCB), your test lab and US counsel. For scope, definitions and Conditional Approvals, see FCC Covered List and robots: Canada vs the US.

What you can do, what you can't, and what is unclear

The left column is in the FCC's own documents. The middle column follows from the text of 47 CFR. The right column is where we found nothing specific, so don't decide it yourself.

Why repair is fine and changes are not

An FCC equipment authorization covers a model in a specific configuration. Under 47 CFR 2.903(a), equipment on the Covered List cannot obtain an equipment authorization, whether by certification or Supplier's Declaration of Conformity. For models already authorized, the FCC fact sheet is direct: the action "does not prohibit the import, sale, or use of any existing models" the FCC previously authorized, "does not affect any previously purchased devices", and the restrictions "apply to new device models."

The problem is modification. Makers normally change an authorized product through the three permissive change classes in 47 CFR 2.1043: Class I (no degradation of reported characteristics, no filing), Class II (degraded but still compliant, filing required and no marketing until the FCC accepts it) and Class III (software-defined radio changes to frequency range, modulation or power). But both 2.1043(b) and 2.932(b) begin "Except for equipment prohibited from authorization pursuant to § 2.903". Once robots were added to the Covered List, models authorized before July 28 became covered equipment too, so the permissive change route closed. The only other route is a new certification, which 2.903(a) blocks.

Repair and identical-part replacement are different because they don't change the authorized configuration. The FCC robot FAQ (updated October 27, 2026) says: "The Covered List rules do not prohibit the repairs of already-authorized devices that consumers currently possess," and they "also do not prohibit the replacement of component parts with identical parts that are installed in already-authorized devices."

Two more points. DA 26-786 says the robot entry is identified "by place of production, not by entity", so the October 13, 2026 rules aimed at Covered List entities (such as 2.932(f)) do not reach robot makers as such. And the new component rule in 2.903(b)(2) "applies prospectively to new equipment authorization applications; it does not affect previously authorized equipment" (91 FR 57798).

Replacing parts: identical part or a change?

Before a technician swaps anything on a US robot, work through this order:

1. Is it the original part number and specification? Then it is identical-part replacement, which the FAQ says is not prohibited. Keep a record: robot serial number, FCC ID, part numbers and lot of the removed and fitted parts, date and photos.
2. Different part number that the factory calls "equivalent"? Stop. A discontinued part, a new supplier or a board revision may no longer be an identical part. Have the grant holder (usually the manufacturer) and a TCB decide before anything is fitted.
3. Does it involve RF, antennas, the main controller, compute or sensors? A non-identical replacement there is effectively blocked under 2.932(b) and 2.1043(b). The workable options are to find the original part (stock, used parts, a last-time buy) or to petition the FCC for a waiver. On October 22, 2026 the FCC's Office of Engineering and Technology gave Intel a one-year waiver (DA 26-1146) to make hardware changes to the specific AGVs listed in its petition, in its own US plants, on the representation that the changes would not improve RF characteristics, alter functionality or replace a US-made component with a foreign one. It applies only to Intel.
4. Is the robot made in the US? Check domestic content before fitting an imported part: a domestic end product under 48 CFR 25.101(a) needs domestic components above 65% of cost for 2024–2028 deliveries and 75% from 2029. The FCC's 91 FR 57798 preamble says the prohibition reaches a change that would cause a device to lose domestic end product status.
5. Only a housing, tire, brush or filter with no electronics? Same part number, swap it. Whether a non-electronic part with a different part number counts as a change is not addressed; we would stock original numbers anyway and ask a TCB if unsure.

Our reading (not rule text): the FCC's safe zone is "repair" and "identical parts", nothing wider. That changes what US spare-parts stock is worth. A missing part used to mean waiting for a new part number; now, once the original part is gone, there may be no compliant way to repair that robot in the US. The most useful thing to do is to stock the critical parts while the original numbers are still available.

Software and firmware updates: what the waiver covers

DA 26-789 (July 28, 2026, Office of Engineering and Technology) says covered robots authorized before July 28 "may continue to receive software and firmware updates that mitigate harm to U.S. consumers at least until January 1, 2029," including "all software and firmware updates to ensure the continued functionality of the devices, such as those that patch vulnerabilities and facilitate compatibility with different operating systems." It waives the prohibition on Class I and Class II permissive changes for those updates. Four things to watch:

• Only the prohibition is waived. The notice says grantees must still meet the Class II requirements: complete information and test results, minimum performance under the rules, no marketing of the modified equipment before the FCC acknowledges the change, and a certification that the device is not prohibited from authorization.
• Only the grant holder can make Class I and II changes (2.1043(b)(4)). A dealer, integrator or service partner can carry out an update on site, but the grantee releases it and answers to the FCC.
• New features are a grey area. The examples in the notice are continued functionality, vulnerability patches and compatibility. Whether a feature release, especially one touching RF parameters, still "mitigates harm" is not stated; ask a TCB first. Changes to frequency range, modulation or maximum power are Class III and outside the waiver.
• January 1, 2029 is a floor, not a promise. The comparable drone waiver originally ran to January 1, 2027 and was extended in May 2026 to at least January 1, 2029 (DA 26-454, as described in DA 26-789). Whether the robot waiver will be extended is unknown.

In practice: for every US firmware release, write down what changed, whether it affects RF emissions, and which change class it is. That record may matter more than the code. Push updates through the customer's change process too; see robot IT security requirements in North America.

Risks that remain for authorized models

• The FCC can restrict authorized equipment. FCC 25-71 (2025) set up a process to restrict previously authorized covered equipment, and it has been proposed for some drones. As of November 7, 2026 we have seen no such action on robots, but watch for it.
• Models pending on July 28. Law firm analyses say these are not protected, even if units are already in a US warehouse. Check the grant date on the FCC ID.
• Selling a revised model under the old grant. If the hardware changed, shipping it under the original FCC ID means selling unauthorized equipment.

Canada works differently

FCC rules have no force in Canada. Radio certification there is ISED's, under RSP-100 (Issue 12): Class I permissive changes (no change to fundamental RF characteristics; generally no notice to ISED unless the HVIN or PMN changes), Class II (notice required), Class III (firmware changes affecting RF) and Class IV remain available, and a host that uses only certified modules for all intentional emissions does not need its own certification (handheld and wearable hosts have separate rules). As of November 7, 2026 we have found no Canadian measure similar to the Covered List.

That creates a parts-management problem: the same model can take a design change in Canada through ISED, while the US fleet has to stay in its FCC-authorized configuration. Keep separate US and Canadian part numbers, and never send a Canada-revision part to a US site. Canadian requirements are covered in robot certification in Canada.

Action list for robot makers

1. Inventory the US fleet: serial number, model, FCC ID, grant date (before or after July 28, 2026), customer and site for every robot.
2. Freeze the US bill of materials: lock part numbers for RF, antennas, controller, compute and sensors; route every substitute through a change review that includes someone who knows FCC rules.
3. Buy critical parts while the originals exist: size stock to 2029 from fleet size and failure rates, and place last-time buys for parts going end-of-life. Consignment with a local partner is one way to hold it: see robot spare parts consignment in Canada.
4. Document every swap: removed and fitted part numbers, lots, serials and photos, so you can show it was an identical part. A ticket and RMA format is in robot warranty and RMA in North America.
5. Classify software releases: ship maintenance and security fixes as separate releases, state whether RF is affected, and check feature releases with a TCB first.
6. Run two configurations: Canada can change, the US can't. Label spares, firmware branches and documents by country.
7. Fix on site rather than shipping whole robots home: bringing a repaired, unchanged authorized robot back into the US is not prohibited, but the round trip takes weeks and a non-identical part fitted at the factory turns it into a change. Module swaps, calibration and maintenance can be done locally; when a return is unavoidable, see returning a robot to the manufacturer in China.
8. Tell customers and put it in the contract: robots already sold in the US can still be repaired, fitted with original parts and updated; service contracts should say spares are original part numbers only and software updates come from the manufacturer.

Where KeepRobots fits

KeepRobots is a robot field service company based in Vancouver. We don't provide legal or certification services: whether a part is identical or which class a software change falls into is for the manufacturer and its certification body to decide. Within that, we can:

• diagnose, repair and maintain robots at US and Canadian customer sites, fitting only the original part numbers in your manual, with a site report listing part numbers, serials and photos for every job
• hold your North American spare parts in Vancouver, with US and Canadian part numbers kept apart
• carry out firmware updates on site with your team and run acceptance tests afterwards (you release the version)
• work in English and Chinese, read Chinese technical documents and overlap with factory working hours

Rates before tax: diagnostic US$200 or C$200 per robot, per visit, credited against an approved repair; on-site labour US$150 or C$150 per hour; C$100 call-out per visit in the Greater Vancouver core zone; US travel and travel outside the core zone quoted per project. How we reach US sites and what a service call includes: robot repair and field service in the USA and robot repair and maintenance. Or write to partners@keeprobots.com.

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FAQ

Can robots already sold in the US still be repaired after the FCC Covered List?

Yes. The FCC robot FAQ says the Covered List rules do not prohibit repairs of already-authorized devices or the replacement of component parts with identical parts. The FCC fact sheet says the action does not prohibit the import, sale or use of previously authorized models and does not affect devices already purchased. The model must have been authorized before July 28, 2026.

Are there limits on replacement parts?

Identical parts, meaning the original part number and specification, are fine. A non-identical part (a substitute, a different radio module or antenna, a different compute board) is a change to the authorized device; covered equipment cannot use Class I or II permissive changes (47 CFR 2.932(b), 2.1043(b)) and new grants are blocked by 2.903(a), so it is effectively not possible. Whether a same-function part from a new supplier or a non-electronic part with a new number counts as a change is not addressed for robots; ask a TCB.

Can we still push software and firmware updates to robots in the US?

Yes. DA 26-789 waives the prohibition on Class I and Class II permissive changes for software and firmware updates that mitigate harm to US consumers, including updates for continued functionality, vulnerability patches and OS compatibility, on robots authorized before July 28, 2026, at least until January 1, 2029. Class II filing rules still apply and only the grant holder can make Class I or II changes. Check feature releases and anything touching RF parameters with a TCB.

What happens to software updates after January 1, 2029?

Unknown. The notice says "at least until January 1, 2029". A similar drone waiver was extended in May 2026 from January 1, 2027 to at least January 1, 2029; whether the robot waiver will be extended depends on future FCC action.

What if the original part is discontinued?

Look for the original part number first: stock, used parts or a last-time buy. Fitting a non-identical part needs the grant holder and a certification body to assess it, and today it is mostly blocked. There is one case-by-case precedent: DA 26-1146 (October 22, 2026) gave Intel a one-year waiver for hardware changes to listed AGVs in its own US plants, which applies only to Intel.

Does Canada have the same restrictions?

As of November 7, 2026 we have found no similar Canadian measure. ISED certification under RSP-100 still allows Class I to IV permissive changes. Because the same model's US units must stay in their FCC-authorized configuration, keep separate US and Canadian part numbers.

Can KeepRobots service robots already installed in the US, and what does it cost?

Yes, per project from Vancouver, with Greater Vancouver as our home base in Canada. We fit only original part numbers from your manual, report part numbers and photos for every job, can hold North American spares and carry out firmware updates on site. We don't make legal or certification calls. Before tax: diagnostic US$200 or C$200 per robot, per visit, credited against an approved repair; labour US$150 or C$150 per hour; C$100 Greater Vancouver call-out; US travel quoted per project.

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Sources

• FCC Public Notice DA 26-786 (July 28, 2026), robots added to the Covered List: docs.fcc.gov
• FCC fact sheet (July 28, 2026): docs.fcc.gov
• FCC OET DA 26-789, waiver for software and firmware permissive changes: docs.fcc.gov
• FCC Covered List FAQs, robots and inverters (updated 2026-10-27, read 2026-11-04): fcc.gov
• 47 CFR 2.1043, changes in certificated equipment: ecfr.gov
• 47 CFR 2.932, modification of equipment: ecfr.gov
• 47 CFR 2.903, prohibition on authorization of Covered List equipment: ecfr.gov
• 91 FR 57798 (FCC 26-50, effective October 13, 2026): federalregister.gov
• 48 CFR 25.101, domestic end product: ecfr.gov
• FCC OET DA 26-1146 (October 22, 2026), Intel AGV maintenance waiver: docs.fcc.gov
• FCC 25-71, process to restrict previously authorized covered equipment: docs.fcc.gov
• ISED RSP-100 Issue 12, certification of radio apparatus: ised-isde.canada.ca

A summary of public documents checked on November 7, 2026; "our reading" marks interpretation. Not legal or certification advice: confirm part changes and software changes for your product with a TCB, your test lab and US counsel. KeepRobots rates are current published rates, before tax, and may change.

中文版：FCC 新规后新品进不了美国：已经卖出去的机器人还能修、能换件、能升级软件吗