Morrison & Foerster·SANCTIONS / EXPORT CONTROLS

FCC Adds Advanced Robotics to 'Covered List' Import Ban

The move effectively bars new models of many foreign-made autonomous ground-based systems from being imported or sold in the US, citing national security risks.

The US Federal Communications Commission (FCC) on July 28, 2026, added foreign-produced advanced robotic devices to its "Covered List," effectively banning new models from the US market. The prohibition applies to equipment requiring FCC authorization for importation or sale, which includes most robotics systems. This action continues the FCC's trend of targeting entire product categories deemed a national security risk, not just specific companies, and is widely seen as aimed at Chinese technology.

Sophisticated counsel should advise clients that the ban disrupts supply chains and creates significant contractual and compliance risks. The definition of "advanced robotic device" is broad, capturing many autonomous or semi-autonomous mobile systems. A product is deemed "foreign-produced" if it fails to meet the domestic content cost thresholds used in federal procurement. While existing device authorizations are grandfathered, even minor modifications to these products may trigger the ban. Companies should immediately audit their product portfolios, supply chains, and contractual representations to assess exposure and mitigate risk. A difficult conditional approval process exists, but affected parties should also monitor for potential FCC refinements to the listing's scope.

fcccovered-listroboticsnational-securityinternational-tradesupply-chainimport-controlssecure-networks-act
Read the original firm alert → Saturday, September 5, 2026

Stay ahead

Join the digest.

One email when the daily AmLaw 100 briefing ships. No noise, no pitch decks — just the grade 4–5 signal.