What insurance does a robot company need to sell in North America?

Short answer: To sell robots in the US and Canada, the core policy is a commercial general liability (CGL) policy that covers both countries and includes products-completed operations. What North American customers actually ask for is a certificate of insurance (COI), usually on an ACORD 25 form, plus the endorsement that names them as an additional insured. On top of that, add layers as your business needs them: technology errors and omissions (Tech E&O) and cyber if your robots depend on cloud software, remote operations or OTA updates; cargo for units in transit; workers' compensation for anyone working on site (WorkSafeBC in British Columbia, state systems in the US); commercial auto for technicians who drive to sites; and an umbrella or excess policy when a large customer asks for higher limits.

An export product liability policy from a Chinese insurer can work, but customers' legal and procurement teams will check whether the insurer is recognised locally, whether the policy's territory and jurisdiction include the US and Canada, who handles a claim and defence locally, and whether the policy can produce a COI and the endorsements they ask for. A common setup is a home-country policy for global risk plus a local North American policy, bought through a North American subsidiary or broker, that is used to issue COIs to customers.

KeepRobots is a robot field service company in Vancouver serving Canada and the United States. We don't sell insurance and we are not brokers or lawyers. This note explains how insurance usually comes up when a robot maker sells, demos and services robots in North America, based on the public sources listed at the end (checked 2026-10-20). It is not legal or insurance advice; confirm everything with a licensed broker and a lawyer.

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What a COI is, and what it is not

A COI is a one-page summary of your policies: the insurers, policy numbers, effective dates and limits. IRMI defines it as a document that proves you have bought certain types and amounts of insurance. The most common format in the US is ACORD 25.

A COI is not the policy. ACORD 25 carries a disclaimer that the certificate is issued for information only, confers no rights on the holder, and does not amend, extend or alter the coverage. A New York Department of Financial Services legal opinion makes the same point: such certificates evidence coverage but cannot change policy terms. The law firm Miller Nash puts it more bluntly: a COI that says a company is an additional insured does not make it one. Only an endorsement issued by the insurer does.

That is why a customer's procurement or facilities team usually asks for two things: a COI naming the customer's legal entity as certificate holder, and a copy of the additional insured endorsement. Issuing a COI is quick once you have a suitable policy. The slow part is buying a policy the customer will accept, which is why insurance often holds up the first North American demo or site visit.

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Who is responsible for what

After an accident, North American plaintiffs' lawyers usually name everyone in the chain: the manufacturer, the importer, the dealer, the company that installed or serviced the robot, and sometimes the site owner. Whether a given policy pays depends on how the damage was caused. A Hankun Law article on export product liability insurance gives an example: if an accident was actually caused by faulty installation rather than a manufacturing or design defect, a product liability claim may not succeed. So keep "whose liability" and "whose insurance" separate.

This table describes the usual pattern. The actual allocation is set by your contracts and the law where the incident happens. For how the same four parties split warranty costs, see robot warranty and RMA in North America.

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The policies, one by one

1. CGL with products-completed operations

North American CGL policies are mostly on ISO forms. As IRMI explains, a CGL policy has an each-occurrence limit, a general aggregate, and a separate products-completed operations aggregate. That last one covers bodily injury and property damage away from your premises caused by products you have handed over and work you have finished. The two aggregates are separate and do not erode each other.

For a robot maker, products-completed operations is where most of the risk sits: a robot that strikes a person, damages racking or starts a fire after delivery falls here. When you buy, check that it is not excluded and that the limit is not token.

2. Export product liability from a Chinese insurer: four things to check

Hankun Law's series on export product liability insurance (in Chinese) separates three concepts: the territory covered (for example "USA and Canada", or "worldwide excluding USA and Canada"), the jurisdiction (where a third party's lawsuit must be brought for it to count, which has to include the territory), and the governing law of the policy itself (which country's law and courts apply to a dispute between you and your insurer). A policy that says "Chinese law applies" without matching territory and jurisdiction may not respond to a North American lawsuit at all.

Three more points from the same series: export policies are often written on a claims-made basis, so the retroactive date and extended reporting period matter; liability policies issued by Chinese insurers usually do not automatically cover punitive damages; and recall costs are normally excluded and need separate recall cover. Foreign dealers not being named as additional insureds is a common gap.

One common confusion: China Export & Credit Insurance Corporation (Sinosure) lists export credit insurance, overseas investment insurance, guarantees and credit information among its businesses. These protect against a buyer not paying and against political risk, not against a product injuring someone. They do not replace product liability insurance.

3. Technology errors and omissions (Tech E&O)

IRMI describes Tech E&O as insurance designed for providers of technology services and products. It covers pure financial loss: your product does not perform as promised, or an error in your service costs the customer money, for example a fleet scheduling bug that stops a warehouse line for a day. A standard CGL policy usually does not pay these claims because there is no physical damage. Customers increasingly ask about it for robots with cloud dispatch, remote operation or OTA updates.

4. Cyber

Robots carry cameras, LiDAR, Wi-Fi and cloud connections, so they bring data breach and intrusion risk. Cyber policies generally have a first-party part (your own forensics, data restoration, notification and business interruption) and a third-party part (claims from customers or regulators). Customers that handle sensitive data may write a cyber limit into the contract.

5. Cargo

Demo units, production shipments and returned parts are covered in transit by cargo insurance. Under Incoterms 2020, CIF only requires the seller to insure on the minimum Institute Cargo Clauses (C), while CIP requires the broader Clauses (A). Robots are high-value precision equipment, so do not assume the CIF minimum is enough. Also write down who owns and insures the robot once it arrives at the customer's site.

6. Workers' compensation: WorkSafeBC and US states

• Check clearance letters for contractors in BC. WorkSafeBC says that if a registered contractor you hire does not pay its premiums, you may be liable for the premiums on the work it did for you. Check the contractor's clearance letter before the work starts and again when it ends.
• Bringing staff from outside BC. Employers from outside the province whose workers work in BC beyond a set number of days may need WorkSafeBC coverage; follow WorkSafeBC's out-of-province rules. If you fly engineers in from China for a deployment, confirm in advance how their injury and medical cover works, because a Chinese work-injury scheme may not reach them.
• The US is state by state. Rules differ by state; Texas, for example, lets private employers choose not to carry workers' compensation (nonsubscribers). Follow the state's rules and your customer's contract.

7. Commercial auto

Technicians driving to sites and carrying parts need auto cover. In BC, ICBC Basic insurance is mandatory for vehicles and includes $200,000 of third-party liability; higher limits can be bought as Extended Third Party Liability. Customer contracts often require owned, hired and non-owned vehicles to be covered.

8. Umbrella and excess

When a customer requires more than your primary CGL limit, an umbrella or excess policy sits on top. IRMI explains that "follow form" means the umbrella or excess policy follows the terms of the underlying policy, and such policies generally require you to keep the underlying insurance in force. Check where it follows form and where it adds its own exclusions.

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Four contract requirements you will see most

• Additional insured. IRMI defines it as a person or organisation not automatically included as an insured that is added at your request. Makers commonly give dealers the ISO vendors endorsement (CG 20 15), which covers the dealer for liability arising from your product. According to CLM, that endorsement generally does not cover installation, service or repair the dealer performs away from its own premises, so dealers that also do field service need separate arrangements.
• Waiver of subrogation. Your insurer gives up its right to recover from the other party after paying a claim. IRMI notes that a waiver agreed before a loss generally does not affect coverage, while waiving rights after a loss can void coverage under many policies. Have your broker add the endorsement when the contract is signed.
• Primary and non-contributory. IRMI explains this sets which policy pays first when several apply. The customer usually means "your policy pays first and you don't come after mine".
• Limits. There is no legal standard; the customer's contract sets them. One public example is Tufts University's vendor requirements: CGL of $1 million per occurrence and $2 million aggregate including products and completed operations, a $5 million umbrella where required, $2 million cyber for vendors handling protected data, and $500,000 employer's liability. "$1M / $2M plus a $5M umbrella" is common in North American supplier contracts, but it is common practice, not a legal requirement. Large retail, logistics and hospital customers may ask for more.

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Will a North American customer accept a Chinese policy?

Two terms first: an admitted insurer is licensed in the state or province; a non-admitted insurer is not. In the US, a non-admitted foreign (alien) insurer can only be placed through a licensed surplus lines broker, and the insurer must appear on the NAIC Quarterly Listing of Alien Insurers, as the Maryland Insurance Administration explains. In British Columbia, the Insurance Council of BC says licensed agents may not solicit insurance from unauthorized insurers and may only arrange it when the client instructs them to, consents in writing and receives a risk disclosure; and the BC government says residents, including businesses with a permanent establishment in BC, that buy from unlicensed insurers must self-assess 7% insurance premium tax.

In practice, customers reject home-country policies for these reasons:

1. Their risk team does not recognise the insurer and cannot find a rating or local licence.
2. The policy is in Chinese, or the translation is not accepted.
3. The insurer cannot issue an ACORD-style COI, add additional insureds, or provide waiver of subrogation and primary/non-contributory endorsements.
4. The territory or jurisdiction excludes the US and Canada, or the governing law and courts are Chinese.
5. Nobody can say who takes the claim and appoints local defence counsel if something happens in North America.

The usual compromise is a home-country policy covering worldwide risk (including the US and Canada) plus a local North American policy used to issue COIs. Whether you need both layers and how they fit together is a question for your Chinese and North American brokers together.

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US and Canadian litigation risk is different

• United States: the Seventh Amendment preserves the right to a jury trial in common-law civil suits, and Rule 23 of the Federal Rules of Civil Procedure provides for class actions. Juries, punitive damages and class actions together are generally seen as the main reasons US product liability risk is high.
• Canada: according to the Chambers Product Liability and Safety 2026 guide for Canada, the Supreme Court of Canada capped non-pecuniary damages (pain and suffering) in 1978, indexed to inflation, at roughly C$460,000 as of July 2025; punitive damages are available only in rare and exceptional cases. Class actions are common in Canadian product liability cases too, and in Quebec punitive damages can be claimed under the Consumer Protection Act.

Canada carries less risk than the US, but not none. If you pilot in Canada before entering the US, put US territory into the policy early rather than discovering after the first US contract that it is excluded. For the market-order question, see US or Canada first under the FCC Covered List.

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Insurance by stage

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Insurance clauses for your service partner agreement

Read the insurance and indemnity clauses together. The aim is that any indemnity you ask a partner to give falls within what the partner's policy will actually pay. A standard CGL policy's "insured contract" coverage is limited to tort liability of another party that you assume by contract, meaning liability the law would impose without the contract. Liability created only by the contract may not be insured.

At minimum, write down:

• Policies and minimum limits: CGL with completed operations, workers' compensation (in BC, WorkSafeBC registration in good standing), commercial auto, and E&O where relevant.
• Additional insured: the maker (and the end customer, if its contract requires) for both ongoing and completed operations.
• Waiver of subrogation and primary/non-contributory: endorsed before the contract is signed.
• COI and endorsement copies: renewed after each policy renewal, with advance notice of cancellation or reduced cover written into the contract (the COI itself does not guarantee you will be notified).
• Indemnity boundaries: the service partner answers for its own workmanship, the maker for product defects, each backed by its own insurance. Don't push liability onto a party far beyond what its policy covers; it will not be able to pay.
• Subcontractors: the same insurance and WorkSafeBC clearance for anyone the partner subcontracts to.

Asking for a COI and a WorkSafeBC clearance letter is the first step when choosing a partner. The rest of the list is in our service partner checklist and the service SLA guide.

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Why humanoids and quadrupeds are harder to insure

• No loss history. Underwriting runs on claims data, and humanoids and quadrupeds have almost none in North America. The Asia Business Daily reported in October 2026 that Lloyd's considers the risks of physical AI robots should be assessed on their own technical characteristics rather than covered only by existing general liability policies, and named pricing based on real-time operating data as one direction.
• Blurred responsibility. When an autonomous decision goes wrong, it is hard to say whether the algorithm, a sensor, the site, an operator or a repair was at fault. Insurers will look hard at your safety design, test records, remote logs and incident investigation capability.
• Chinese products are only starting. Chinese insurers have begun offering dedicated cover for humanoid or embodied-AI robots, for example a CPIC product launched in October 2025 covering manufacturing, sales, leasing and operation. These are domestic products; whether they can be shown to North American customers depends on the checks in the previous section.

Practical tip: give insurers your safety design documents, certification status, speed and zone limits, remote monitoring and logging, and field maintenance records. The more complete the file, the easier it is to get a quote. For the service side of humanoids, see humanoid robot repair in North America.

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What drives the premium

We give no numbers here; they vary too much by product and company, and only a broker quote counts. Published underwriting guides typically list:

• The product's own risk: weight, speed, close contact with people, use in medical, child or food settings;
• Sales volume and where you sell, especially the US share;
• Recall, litigation and incident history, and claims record;
• Company size and financial condition;
• Quality control and safety management, which can earn credits;
• The limits and deductibles you choose: higher limits cost more, higher deductibles cost less.

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Common pitfalls

1. Sending a COI without the endorsement. The customer's lawyer checks and finds the additional insured status was never issued.
2. Territory "worldwide excluding USA and Canada". A common wording in export policies; choose it and North American incidents are not covered.
3. Product liability only, nothing for on-site work. If your own staff install or repair robots, an incident may be an operations claim that a product liability policy does not pick up.
4. A claims-made gap. Changing insurers without carrying over the retroactive date leaves robots sold earlier uninsured.
5. Waiving subrogation after a loss. This can void your own coverage.
6. Using a local contractor that has not paid premiums. In BC you may be assessed its WorkSafeBC premiums, and a work injury can turn into a lawsuit.
7. Settling without the insurer's consent. Hankun Law warns this can lead the insurer to refuse the settlement amount.

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What KeepRobots can do

KeepRobots provides robot field service from Vancouver: deployment and commissioning, hourly on-site repair, preventive maintenance, pre-sales demos and spare parts storage, mainly in British Columbia and Metro Vancouver, with travel to the rest of Canada and the US. We don't sell insurance and don't replace your broker or lawyer. But in demo, pilot and after-sales work we can help you prepare for the insurance questions North American sites usually ask, before the site visit is booked. Published rates: diagnostic fee C$200 in Canada or US$200 in the US, per robot, per visit (credited if you approve the repair), a C$100 call-out fee in the Metro Vancouver core area, and on-site labour at C$150 or US$150 per hour, taxes extra; travel outside the core area and US projects are quoted per project. See after-sales and deployment partnership for robot makers and robot deployment in Canada and the USA.

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FAQ

What insurance does a robot company need to sell in North America?

The core is a commercial general liability (CGL) policy covering the US and Canada that includes products-completed operations and can issue certificates of insurance with additional insureds. Add Tech E&O and cyber for cloud or remote operations, cargo for shipments, workers' compensation for anyone working on site (WorkSafeBC in BC), commercial auto for technicians who drive, and an umbrella or excess policy when customers require higher limits.

What is a certificate of insurance (COI) and is it enough?

A COI, commonly on an ACORD 25 form, lists your policies, insurers, dates and limits. It is for information only: it gives the holder no rights and does not change the policy. A COI that names someone as an additional insured does not make them one; that takes an endorsement from the insurer. Customers therefore usually ask for the COI plus a copy of the additional insured endorsement, and sometimes waiver of subrogation and primary/non-contributory wording.

Will a US or Canadian customer accept a product liability policy from a Chinese insurer?

Not always. Check that the territory and jurisdiction include the US and Canada, what governing law and courts the policy names, whether punitive damages are covered (Chinese policies usually do not cover them automatically), whether the insurer can issue an ACORD-style COI and additional insured endorsements, and who handles claims and defence locally. In the US a non-admitted alien insurer must be placed through a surplus lines broker and appear on the NAIC Quarterly Listing of Alien Insurers. Many makers keep the home policy as a backstop and buy a local North American policy for customer COIs.

What insurance limits do North American customers usually require?

There is no legal standard; the customer's contract sets them. CGL of $1 million per occurrence and $2 million aggregate plus a $5 million umbrella is common in supplier contracts, with cyber limits for vendors that handle sensitive data. That is common practice, not a rule; large retail, logistics and hospital customers may require more.

What insurance clauses belong in a contract with a local robot service partner?

Minimum limits for CGL with completed operations, workers' compensation (in BC, WorkSafeBC registration in good standing, with clearance letters checked before and after the work) and commercial auto; the maker and end customer as additional insureds; waiver of subrogation and primary/non-contributory endorsed before signing; updated COIs and endorsements after each renewal; indemnities that match what each party's policy covers; and the same insurance for subcontractors.

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Sources

• IRMI, certificate of insurance: irmi.com
• New York Department of Financial Services, OGC opinion 02-12-04 (ACORD certificates evidence coverage and cannot alter the policy): dfs.ny.gov
• Miller Nash, Why you need more than just a certificate of insurance: millernash.com
• IRMI, How the limits apply in the CGL policy (products-completed operations aggregate): irmi.com
• IRMI, additional insured: irmi.com
• CLM, Additional insured endorsements (vendors CG 20 15 and CG 20 10): theclm.org
• IRMI, waiver of subrogation: irmi.com
• IRMI, primary and noncontributory: irmi.com
• IRMI, follow form: irmi.com
• IRMI, technology errors and omissions insurance: irmi.com
• Today's General Counsel, Tech E&O insurance 101: todaysgeneralcounsel.com
• PropertyCasualty360, Contractual liability insurance (insured contract definition): propertycasualty360.com
• Tufts University, insurance requirements for vendors, contractors and service providers (public example): tufts.edu
• ICC Academy, Incoterms 2020 CIP or CIF (insurance conditions): iccwbo.org
• WorkSafeBC, contractors and subcontractors: worksafebc.com
• WorkSafeBC, out of province: worksafebc.com
• Texas Department of Insurance, workers' compensation nonsubscribers: tdi.texas.gov
• ICBC, Basic insurance: icbc.com
• Maryland Insurance Administration, surplus lines insurers (alien insurers and the NAIC Quarterly Listing): maryland.gov
• Insurance Council of BC, Doing business with unauthorized insurers: insurancecouncilofbc.com
• Government of BC, unlicensed insurance (7% insurance premium tax): gov.bc.ca
• Hankun Law, export product liability insurance, part 1 (in Chinese): hankunlaw.com
• Hankun Law, export product liability insurance, part 2: recoverable losses (in Chinese, April 2, 2026): hankunlaw.com
• China Export & Credit Insurance Corporation (Sinosure), business list: sinosure.com.cn
• US Constitution, Seventh Amendment (Cornell LII): law.cornell.edu
• Federal Rules of Civil Procedure, Rule 23 class actions (Cornell LII): law.cornell.edu
• Chambers, Product Liability and Safety 2026, Canada: chambers.com
• The Asia Business Daily, Physical AI era draws near, insurers prepare for new risks (October 15, 2026): asiae.co.kr
• Reinsurance Asia, CPIC launches first dedicated insurance for humanoid robots in China (October 2025): reinasia.com
• Founder Shield, What is product liability insurance rated on?: foundershield.com

Insurance and regulatory information as of 2026-10-25, based on sources checked 2026-10-20. This is not legal or insurance advice; rely on a licensed broker and lawyer. Contract limits quoted are public examples and common practice, not legal requirements. KeepRobots rates are current published rates and may change; taxes, parts and travel outside the core area are extra.

Chinese version: 机器人卖到北美要买什么保险？