FCC Covered List and robots: what it means for robot makers choosing Canada vs the US
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
| Question | What the FCC documents say |
|---|---|
| Effective | July 28, 2026 (DA 26-786, Public Safety and Homeland Security Bureau) |
| Basis | National Security Determination dated July 27, 2026, by an Executive Branch interagency body convened by the White House |
| Covered | Ground-mobile "advanced robotic devices", explicitly including autonomous mobile robots, humanoid robots and quadrupeds |
| Excluded | Fixed 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 models | Cannot receive FCC equipment authorization |
| Previously authorized models | Import, sale and use not prohibited; changes restricted |
| Software/firmware updates | Waiver for updates that mitigate harm to US consumers on devices authorized before July 28, 2026, at least until January 1, 2029 (DA 26-789) |
| Exception | Conditional 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:
- is capable of locomotion, obstacle avoidance, navigation or movement on the ground;
- operates at a distance from a human operator, based on commands, sensor data or both;
- weighs over 4.4 lb together with its ground station or docking station, if it has one; and
- 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.
Conditional Approval. Robot makers can apply to the Department of War for Conditional Approval (submissions go to [email protected]). 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 October 11, 2026 we found three robot Conditional Approvals (DA 26-957, DA 26-996, DA 26-1063, the latest dated October 2): Husqvarna (Sweden) robotic platforms, ANSCER (India) AR-series robotic platforms, and Matic Robots' floor cleaner with its charging dock. These approvals have no fixed end date but depend on the company following its onshoring plan and passing updated vetting.
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 States | Canada | |
|---|---|---|
| Radio certification | FCC | ISED (separate system; foreign applicants need a Canadian representative under RSP-100) |
| New foreign-produced robot models | Blocked unless Conditional Approval or domestic end product | No equivalent measure found as of 2026-10-11 |
| Previously authorized models | Still allowed | Normal ISED rules apply |
| Electrical safety | NRTL-listed marks commonly required (e.g. UL, ETL) | Canadian-accepted marks (e.g. CSA, cUL, cETL) |
| Market size | Much larger | Smaller, but reachable now |
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 a separate (Chinese-language) guide: 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.
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 [email protected]. 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.
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)
- FCC Public Notice DA 26-786 (July 28, 2026), with Appendix C determination and definitions: https://docs.fcc.gov/public/attachments/DA-26-786A1.pdf
- FCC Fact Sheet: https://docs.fcc.gov/public/attachments/DOC-423682A1.pdf
- FCC OET waiver DA 26-789 (software and firmware updates): https://docs.fcc.gov/public/attachments/DA-26-789A1.txt
- FCC Covered List FAQs, robots and inverters: https://www.fcc.gov/covered-list-faqs-robots-inverters
- FCC Covered List: https://www.fcc.gov/supplychain/coveredlist
- FCC 25-71 Second Report and Order: https://docs.fcc.gov/public/attachments/FCC-25-71A1.txt
- Robot Conditional Approvals: DA 26-957 (Sept 9, 2026), DA 26-996 (Sept 18, 2026), DA 26-1063 (Oct 2, 2026), searchable at https://docs.fcc.gov
- ISED RSP-100: https://ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-standards-procedures-rsp/rsp-100-certification-radio-apparatus-and-broadcasting-equipment
- Sidley Austin analysis: https://www.sidley.com/en/insights/newsupdates/2026/08/fcc-adds-all-foreign-produced-advanced-robotic-devices-to-the-covered-list
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.