FCC Covered List: What Equipment Manufacturers and Importers Need to Know

The FCC Covered List no longer just blocks new approvals. Since July 2026, certain previously authorized equipment can no longer be imported or marketed, and further bans are already proposed. Element’s certification experts explain who is affected and what to do next.

What is the Federal Communications Commission (FCC) Covered List?

The Covered List, established under Section 1.50002 of the Federal Communications Commission (FCC) Rules (47 CFR), is a repository of communications equipment and services deemed to present an unacceptable risk to national security. It is maintained by the Public Safety and Homeland Security Bureau (PSHSB) rather than the Commission itself and published on the FCC website. Named entities, together with their subsidiaries and affiliates, are all treated as being on the list.

Equipment on the list cannot obtain a new FCC authorization, whether through Certification or Supplier’s Declaration of Conformity.

 

Named entities

Added between 2021 and 2024, these include product manufacturers such as Huawei Technologies, ZTE Corporation, Hytera Communications, Dahua Technology, Hikvision, and Kaspersky Lab, as well as telecommunications service providers including China Mobile International, China Telecom (Americas), and China Unicom (Americas).

Broad product categories

Since late 2025, the FCC has moved beyond naming specific companies to listing entire product classes produced in any foreign country. The addition date for each matters, and the next section explains why.

• Uncrewed aircraft systems and UAS critical components, added December 22, 2025. Critical components are defined broadly and include flight controllers, ground control equipment, navigation systems, sensors and cameras, batteries and battery management systems, motors, data transmission devices and associated software.
• Consumer-grade routers, added March 23, 2026.
• Foreign-produced power inverters and foreign-produced advanced robotic devices, both added July 28, 2026. Advanced robotic devices cover mobile platforms such as humanoid and quadruped robots.

The list also contracts. Toy drones were removed on June 15, 2026. Anyone relying on a check made months ago should make it again.

 

What does "foreign-produced" actually mean?

This is the most widely misunderstood part of the current rules, and getting it wrong is expensive.

The category listings are country-neutral. The test is not the nationality of the manufacturer. It is whether the article would qualify as a domestic end product under the definition used in federal rules, and the FCC has confirmed that the nationality of the producing entity is not relevant.

Two consequences follow, and both catch companies out. First, a US-headquartered business manufacturing in a third country can produce equipment which would be considered foreign-made. And final assembly in the United States may not on its own be enough to make a product permissible, if substantial foreign content remains.

It is worth noting that all countries outside the US are treated equally. If your compliance position rests on the assumption that these rules only affect Chinese suppliers, it needs to be revisited.

 

Modular transmitters and the component question

The FCC has clarified that a product built in the US containing a small number of foreign-made basic components, resistors or capacitors, for example, is not itself considered to be on the Covered List. That clarification does not extend to modular radio transmitters or to logic-bearing hardware components, meaning microprocessors.

Any new product not yet authorized that incorporates a covered modular transmitter or microprocessor is ineligible for authorization, regardless of whether the end product is foreign-made or not. This holds whether the product would ordinarily go through Certification, through Supplier’s Declaration of Conformity, or would ordinarily be exempt from authorization altogether. One covered module removes the whole product from eligibility. The only route to authorization is to remove or replace that component, which is a hardware change and therefore, for any existing products, is a permissive change question in its own right.

 

Why previously authorized products are no longer safe

Under the FCC rules, once a product type is properly authorized, identical units can be marketed indefinitely in the US until the rules for that product type change. Such changes are infrequent, so FCC authorizations have long been treated as effectively valid forever.

The term often used is grandfathering. This differs sharply from the European approach, where every unit leaving the production line must meet the requirements in force at that time, regardless of any prior approval for the same product type. Our FCC and ISED certification webinar covers this difference in more detail.

The Commission has always been able to revoke an existing authorization through an adjudicatory process. Rule part 2.939(e), effective December 2025, went further and gave PSHSB and the Office of Engineering and Technology (OET, the division of the FCC responsible for product authorization) the power to place limitations on existing authorizations unilaterally. For several months that power sat unused.

It was exercised for the first time in 2026. Following a comment period opened on March 27, PSHSB and OET released Public Notice DA 26-635 on June 26, 2026, prohibiting the continued importation and marketing of covered equipment added to the Covered List in 2024 or earlier.

The notice was published in the Federal Register on July 6 and the prohibition took effect on July 16, ten days later. That is unusually quick; thirty days or more is the norm. The Bureau declined a phased implementation, reasoning that any advance warning would let affected companies flood the market with banned products before the ban took effect.

In its own words, there were no public-interest factors that outweighed the proposed ban. Hikvision challenged the Commission’s legal authority to limit existing authorizations and the Bureau rejected the argument.

Read the scope carefully, because it is narrower than the headlines suggested. The June ban reaches equipment listed in 2024 or earlier, which means the named entities only. Drones, routers, power inverters and advanced robotic devices were all listed after 2024 and are not covered by this ban.

That distinction is already closing. Two further proceedings are open: DA 26-742, released July 17, 2026, and DA 26-758, released July 21, 2026, which proposes extending the prohibition to previously authorized military-grade UAS and UAS critical components. Anyone holding stock or supply commitments in the post-2024 categories should plan on the assumption that a similar ban will follow.

 

Can you still update a product that is on the Covered List?

Partly, and the detail matters more than any other point in this article.

The Commission revised rules 2.932(b) and 2.1043(b) in late 2025 to exclude equipment prohibited from authorization from the certification procedures that allow permissive changes. On its face, the rule removes every permissive change route, including Class I changes, which ordinarily require no filing at all. For a manufacturer with a long-lived product on the market, that would mean being unable to issue even a security patch.

OET has waived that outcome, but only within limits. Waivers were issued for covered UAS and critical components in January 2026 and for covered routers in March 2026, permitting software and firmware updates that mitigate harm to US consumers. In May 2026, those waivers were extended to at least January 1, 2029 and expanded to cover analogous Class II permissive changes. Products authorized before their category was added to the list may continue to receive updates that keep them working, including vulnerability patches and operating system compatibility fixes.

The practical line is this: you can keep the software up to date, but you cannot redesign the hardware. A change to the radio, the module, or the circuitry has no waiver behind it, and the categories covered by the waivers are UAS, UAS critical components, and routers, rather than every listed product. If you need a hardware change to an affected product, treat re-authorization as the route, scope it early, and ensure it is made in the US.

 

How to check whether your product is affected

Most manufacturers cannot answer this from their existing records, because a bill of materials rarely captures who holds the grant on a module. Work through it in this order.

1. List every radio module and microprocessor in the product, including anything a contract manufacturer sourced on your behalf.
2. For each radio module, find the FCC ID marked on it, then identify the grantee behind that ID. The grantee, not your supplier or distributor, is the entity that matters.
3. Check each grantee and its subsidiaries and affiliates against the Covered List entries on the fcc.gov website.
4. Separately, test the finished product against the broad categories. A product can be caught as a category member even when no individual component is listed.
5. Where a category applies, work through the foreign-produced test rather than assuming manufacturer nationality settles it.
6. Establish the authorization date for your product and compare it with the date its category or supplier was listed. This determines whether the June 2026 import ban already applies to you or whether you sit in one of the open proceedings.
7. Re-run the check frequently. Four categories were added across eight months, and one was removed. A clean result a month ago may not mean a clean result today.

If step two stalls, which is common with modules bought through distribution, an accredited laboratory or TCB can identify the grantee from the module markings and the FCC database.

Can you still import samples for testing?

Yes, and this is worth knowing before anyone cancels a test program. Small quantities of unauthorized devices may be imported solely for product development or testing purposes, provided they are not marketed or sold. The permission sits in rule 2.1204(a)(3).

So a product that cannot currently be authorized can still be sent to an accredited laboratory for evaluation, including the work needed to establish what a compliant replacement design would require. If you are assessing whether removing a covered module solves your problem, you do not need to wait for a rule change to start testing.

 

Exemptions and conditional approvals

Devices within the listed categories may still be used in two circumstances.

The first is the Blue UAS Cleared List, maintained by the Defense Contract Management Agency. Drones on that list are exempt until at least 2027.

The second is Conditional Approval, available to applicants seeking exemption from the restrictions or seeking to maintain an authorization while mitigating national security concerns. Applications go through the FCC and are decided by the Department of War or the Department of Homeland Security. Expect to provide full supply chain disclosure, ownership and governance transparency, component origin detail, evidence of cybersecurity posture, and a plan to transition production to trusted locations. An approval, once granted, lasts up to one year.

This pathway is working in practice rather than sitting on paper. The FCC announced conditional approvals for certain UAS and routers during June 2026.

 

What should you do next?

This depends on your position. Find the statement below that fits.

If you manufacture equipment

Listed in 2024 or earlier. Since July 16, 2026, these products may no longer be imported or marketed. If you have imported since the ban took effect, or are continuing to import now, seek legal advice immediately.

Listed after 2024. Two proceedings are already open proposing to extend the prohibition, so treat a similar ban as likely rather than possible. Depending on the product, begin planning to onshore production, to replace covered modules, or to retire the line. Element is an FCC-recognized test laboratory and certification body and can support authorization of new or modified devices.

Unsure whether you are affected. Work through the checklist above or contact us for support.

If you import or distribute

Products listed in 2024 or earlier. These may no longer be imported or marketed. If you have imported since July 16, 2026, seek legal advice immediately.

Products listed after 2024. Begin phasing these out of the distribution chain, and check whether any of your lines fall within the two open proceedings.

If you specify or purchase equipment

For anything listed in 2024 or earlier, the product may no longer be imported or marketed, so avoid it even where stock remains available. For anything listed after 2024, weigh the likelihood of a similar prohibition before committing to a system you will need to maintain.

Remember that replacement parts are products in their own right. The most common problem arising from this ban is not a new purchase; it is a like-for-like replacement within an installed system that can no longer be legally sourced. During the consultation, the Bureau was asked to reimburse users who were forced to replace entire systems because a single component became unavailable. It declined, stating that the national security risks outweighed the potential economic impacts.

If you are unsure which of these applies to a specific product, Element is an FCC-recognized test laboratory and certification body and can help establish the position. Contact our team. It is also possible to submit an inquiry to the FCC directly, though responses can be slow.

What the Covered List means for your product now

The direction of travel remains consistent even though the details change monthly. The Covered List began as a register of named companies. It now reaches whole product categories defined by where they were produced rather than by who produced them, and since July 2026 it reaches backwards into authorizations already granted. Two further prohibitions are proposed and open for comment.

For manufacturers, the practical shift is that an FCC grant is no longer a permanent asset. It is a position that has to be monitored. The companies handling this well are the ones that know which modules sit within their products, store that information where procurement and compliance can both see it, and recheck it on a schedule rather than in response to news.

Element’s FCC certification and product approvals teams support manufacturers through equipment authorization, including re-authorization after a design change and market access planning across other regions. For the related question of which test laboratories the FCC still recognizes, see our article on the Bad Labs rules and the true cost of compliance testing. We will update this article as the position changes, and you can follow new material at element.com/resources.

The practical test for any manufacturer is simple. If you cannot say today which company holds the grant on every radio module in your products, you cannot say whether those products are still lawful to import. That gap is worth closing before the next set of proceedings concludes, and closing it does not require a rule change or a redesign to begin.

Find out more about Element and our global network of accredited laboratories.

 

References

[1] FCC, List of Equipment and Services Covered By Section 2 of The Secure Networks Act. https://www.fcc.gov/supplychain/coveredlist

[2] FCC PSHSB, Addition of Uncrewed Aircraft Systems and UAS Critical Components Produced Abroad to FCC Covered List, Public Notice DA 25-1086, December 22, 2025.

[3] FCC, Public Notice DA 26-278, addition of foreign-produced consumer-grade routers to the Covered List, March 23, 2026.

[4] FCC OET, Waiver of Prohibitions on Certain Class I Permissive Changes to Covered UAS and UAS Critical Components, Public Notice DA 26-69, January 21, 2026. https://docs.fcc.gov/public/attachments/DA-26-69A1.pdf

[5] FCC OET, extension and expansion of permissive change waivers to January 1, 2029, Public Notice DA 26-454, May 8, 2026. https://docs.fcc.gov/public/attachments/DA-26-454A1.pdf

[6] FCC PSHSB and OET, Prohibit the Importation and Marketing of Previously Authorized Covered Communications Equipment Added to the Covered List in 2024 or Earlier, Public Notice DA 26-635, PS Docket No. 26-72, June 26, 2026. https://docs.fcc.gov/public/attachments/DA-26-635A1.pdf

[7] Federal Register, 91 Fed. Reg. 41023, July 6, 2026, prohibition effective July 16, 2026.

[8] FCC PSHSB and OET, Public Notice DA 26-742, July 17, 2026. https://docs.fcc.gov/public/attachments/DA-26-742A1.pdf

[9] FCC PSHSB and OET, proposed prohibition on previously authorized military-grade UAS and UAS critical components, Public Notice DA 26-758, July 21, 2026. https://docs.fcc.gov/public/attachments/DA-26-758A1.pdf

[10] FCC PSHSB, addition of foreign-produced power inverters and advanced robotic devices to the Covered List, Public Notice DA 26-786, July 28, 2026.

[11] FCC, FAQs on Recent Updates to FCC Covered List Regarding Foreign-Produced Advanced Robotic Devices and Power Inverters. https://www.fcc.gov/covered-list-faqs-robots-inverters