FCC Covered List: How Robot Models Stay Eligible

What did the FCC change for robot buyers?

On July 28, 2026, the FCC's Public Safety and Homeland Security Bureau added all foreign-produced advanced robotic devices to the Covered List through Public Notice DA 26-786. The entry has one exception: devices granted a Conditional Approval by the Department of War. Models launched after the cutoff need that approval to be cleared for the US market.

Many people call that approval a waiver, but the FCC's own term is Conditional Approval, and the distinction matters when you read filings. Earlier authorized models are not swept up in the action. The FCC says the action does not prohibit the import, sale, or use of existing models previously authorized.

For an operator comparing cleaning robots, the question has shifted. It is no longer only which machine scrubs best. It is which exact model holds which FCC authorization, and through which approval path it arrived.

Which robots fall inside the definition?

The definition covers a mechanical mobile device, including autonomous mobile robots, humanoids, and quadrupeds, that weighs more than 4.4 pounds with its docking station and meets sensor, connectivity, and software tests. The connectivity test requires at least 200 kbps. Fixed industrial arms, such as articulated, SCARA, and gantry units, are excluded, as are medical and surgical robotic systems and mobility assistive devices.

K&L Gates reports that the FCC's FAQ confirms robot vacuums and robot lawn mowers are included when they meet the definition. Cooley says the rule appears to apply to many home robotics products, such as robotic vacuums. A commercial floor scrubber should be checked against the same tests before anyone assumes it sits outside the entry.

How is foreign-produced decided?

The notice defines foreign-produced as anything that does not qualify as a domestic end product under 48 CFR 25.101(a). According to K&L Gates, the domestic component share must be more than 65 percent today, rising to 70 percent in 2029. The entry identifies robots by place of production, not by the company that sells them.

That single rule has a practical consequence. A brand's reputation does not decide its status, and a model's build location does. Two units from the same maker can therefore sit on different sides of the line if they are produced in different places.

Do models already authorized keep selling?

For models authorized before the cutoff, yes. Cooley reports that devices authorized before July 28, 2026 can continue to be sold in the US. The trap is a unit that was built or stocked before July 28 without an FCC authorization in hand. Morgan Lewis advises that such products should not be assumed grandfathered.

Check status at the model and FCC ID level, not the product family name. A vendor's catalog page rarely shows the grant date you need, so ask for the record itself.

How does a Conditional Approval get granted?

Only the Department of War evaluates robotics submissions, and DHS has no role in this category, according to Steptoe. Applicants must supply ownership, supply chain, and onshoring information. Applications must be filed by January 1, 2028, with an officer's certification, as Morgan Lewis reports.

Approvals are not permanent. If a company does not follow its onshoring plan, the device can return to the Covered List, according to The One Lab. The record already shows how the process is working. As of October 2026, DA 26-1063, dated October 2, 2026, granted Conditional Approval to Matic Robots' Robotic Floor Cleaner Model 4MA0001 and Charging Dock Model 4DK0008. A later FCC notice, DA 26-1114 dated October 16, 2026, lists Conditional Approvals for Husqvarna 305v IQ, 310v IQ, 420v IQ, and 440v IQ robotic platforms granted September 9, 2026.

What does the software waiver cover, and what does it not?

A separate OET waiver, DA 26-789, lets authorized robots receive Class I and Class II software or firmware changes that mitigate harm, through at least January 1, 2029, according to Morgan Lewis. Steptoe reports that it covers vulnerability patches and operating system compatibility updates. It does not cover hardware changes.

For a fleet, the practical reading is that security and operating system updates can keep moving on approved models. A new sensor, a different drivetrain, or a revised battery is a hardware question, and it belongs back in the model review.

What should you ask a vendor before committing?

Put these questions in writing before a lease or purchase discussion moves forward. Answers should point to a record you can check, not to a sales line.

• Which exact model and charging dock are quoted, and what is the FCC ID for each?
• Was the authorization granted before July 28, 2026, or does it rest on a Conditional Approval, and if so, which DA reference?
• Is the approval tied to an onshoring plan, and what happens to deployed units if that plan is not kept?
• Which firmware changes will be pushed under the software waiver, and through what date does that coverage run?
• Is the model still clear on the FCC Covered List on the day the agreement is signed?

What is still moving?

K&L Gates reports that a July 22, 2026 order closed the component part loophole. A further proposal would cut the R&D import allowance for foreign-produced robots from 4,000 units to 40. That is a proposal, not an adopted rule, so plans should treat it as a risk to watch rather than a settled cap.

Because the list and the approvals change, a status check at signing is not a one-time step. Build a re-check into the schedule for any renewal or expansion.

Where does Service Robot Co. fit?

We work across manufacturers, so the eligibility check is part of site assessment, not an afterthought. Service Robot Co. is OEM neutral and leases robots only, through a 3 year lease with one fixed payment quoted after a site assessment. That payment structure means the model and its authorization record are settled before the number is set.

Our engineers deploy, integrate, train, and service each unit through a nationwide US network, so the same team that checks a model's record also handles go live support and on-site service. One partner, one number, for the whole lifecycle.