On July 28 the FCC added foreign-produced advanced robotic devices to its Covered List (DA 26-786). Equipment on that list can’t get an FCC equipment authorization, and without one a new robot can’t be imported, marketed or sold here. Models authorized before July 28 keep selling. Every new model has to clear the test.
The test doesn’t care who owns the company. The FCC’s FAQ says the producer’s nationality is irrelevant. It asks where the robot was made and what it was made from, and for most robots that comes down to the bill of materials.
Which robots are covered
The definition comes from the national security determination the FCC adopted. A robot is an “advanced robotic device” if it is a mobile machine (the determination names autonomous mobile robots, humanoids and quadrupeds) that:
- can move on the ground, navigate or avoid obstacles;
- operates at a distance from a human operator, on commands, sensor data or both;
- weighs more than 4.4 lb, counting any docking or ground station; and
- contains a sensor that perceives its environment, a network connection of at least 200 kbps in either direction, and software (firmware and model weights included) that controls navigation, perception, data collection or remote command-and-control.
Connected vehicles, rail vehicles, drones, unmanned underwater vehicles, FDA-regulated medical devices and fixed industrial or medical robot arms (articulated, delta, gantry, SCARA) are out. The FAQ says automated guided vehicles can be in even when they follow fixed paths, and a pool robot that also works above the waterline is in. A mechanical platform imported with no compute, sensors or radio isn’t covered, but adding the radio makes it covered equipment.
What “foreign-produced” means
A robot is foreign-produced if it isn’t a “domestic end product” under 48 CFR 25.101(a), the Buy American test federal buyers have used for decades. It has two prongs:
- The robot is manufactured in the United States.
- The cost of its domestic components exceeds 65% of the cost of all its components for items delivered in 2024 through 2028, and 75% for items delivered from 2029.
Buy American has a carve-out for commercial off-the-shelf products. The FCC says it doesn’t apply here, and that off-the-shelf components still count in the math.
The definitions in 48 CFR 25.003 decide how the math works:
- The denominator is component cost. Not the sale price and not your total cost. A purchased part counts at what you paid for it, plus freight to your line and any duty. A part you make yourself counts at its manufacturing cost plus allocable overhead, with no profit. Final assembly and test of the robot itself stay out of it.
- It looks one level down. A component is whatever goes directly into the robot. Each one is domestic or foreign as a whole, by where it was made. You don’t trace the chips inside a board or the magnets inside a motor for this test.
- Unknown origin counts as foreign. If a supplier can’t or won’t tell you where a part was made, it goes in the foreign column.
Two practical points. The FCC doesn’t prescribe paperwork; you certify that the device isn’t covered, and you need enough evidence to stand behind that certification. And plan to 75%. The FAQ quotes the delivery-year language and doesn’t say how it maps onto an authorization filed in 2028 for a robot you ship in 2029.
A design done here doesn’t count by itself. I made that point at length in Designed in the US Is Not Built in the US.
Why the joints decide it for legged robots
Most of a legged robot’s component cost sits in its joints. Each joint is a motor, a gearbox, encoders and drive electronics in one housing. A quadruped carries twelve of them and a humanoid carries far more. Today most of them are imported.
Here’s an illustrative quadruped. The prices are round numbers I picked for the example, not market data.
| Component | Cost | Made in |
|---|---|---|
| 12 joint actuators (12 × $450) | $5,400 | Imported |
| Battery pack | $900 | Imported |
| Lidar and depth cameras | $1,500 | Imported |
| Compute module | $700 | Imported |
| Machined frame and legs | $1,800 | US |
| Main board | $600 | US |
| Wiring harness and connectors | $300 | US |
| Molded shell | $500 | US |
| Fasteners and small parts, origin not documented | $100 | Unknown |
| Total component cost | $11,800 |
Domestic components come to $3,200, or 27%. That’s well short of 65%, even with the frame, board, harness and shell all made here.
Now swap the joints for US-made ones at the same price. Domestic content goes to $8,600, or 73%. (US-made joints usually cost more today. That pushes the share up further, because the extra cost lands on the domestic side.) That clears 65%. It still misses 75%, so a 2029 ship date needs another $250 or more of component cost to move. A US-built compute board would do it.
No other line on that bill moves the number as far. If you’re building a legged robot for the US market, your joint supplier decides whether you pass.
A word on “made here.” The rule asks where a component was manufactured. A relabeled import is still an import. Ask each supplier where the part was manufactured and get the answer in writing, because that answer is the evidence behind your certification.
Other ways through
- Federal buyers. The FAQ says importing, marketing or selling to the federal government is exempt from the Covered List restrictions. Few robot companies sell only to the government.
- Development units. Small batches of unauthorized devices can come in for development or testing under 47 CFR 2.1204(a)(3), as long as they aren’t marketed or sold.
- Conditional Approval. A foreign-produced robot, or a class of them, can be cleared if the Department of War finds it doesn’t pose the risk. Requests go to conditional-approvals@fcc.gov. Expect to show ownership, a component-level bill of materials and a dated plan to move production here.
- Repairs. Repairing an already-authorized robot, or replacing its parts with identical ones, isn’t restricted.
Run your own numbers
The worksheet below starts with the example above. Replace the rows with your own bill of materials: one row per component as it goes into the robot, at your cost. It runs in your browser and nothing you type leaves the page.
Domestic content worksheet
Component cost = what you paid, plus freight to your line and duty. Parts you make yourself: manufacturing cost plus overhead, no profit. Leave out final assembly and test of the robot.
| Component | Cost (USD) | Made in |
|---|
The share has to exceed the threshold. Landing exactly on 65% doesn’t pass.
Where we come in
We make joints. The ISAP-D line is a backdrivable planetary joint for legged robots, designed for US production, and dev kits are orderable now. We designed it to be built here because the joints are the biggest line on the bill for the robots this rule hits hardest. If you’re running this math on a real robot and the joints are where it breaks, write to us at partner@automata.llc.
This is how we read the rule. It isn’t legal advice about your product. The determination, the FCC’s FAQ and 48 CFR 25.003 and 25.101 are the sources, and they’re linked above.