Navigating the FCC Robotics Restrictions
On July 28, 2026, the FCC added foreign-produced advanced robotic devices to its Covered List, restricting new equipment authorizations for robots built outside the U.S.
Fresh helps companies understand what’s covered, plan around it, and keep building with a domestic path forward.
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Support and expertise for an evolving robotics landscape
Traditionally robotic teams built manufacturing and sourcing relationships based on components and product road maps provided by a global supply chain. For Advanced Robotic Devices (ARD), this changed on July 28, 2026, when the FCC added foreign-produced advanced robotic devices (and relatedly, Connected Power Inverters) to its Covered List.
So what does that mean for robotics companies? Under the new rule, robots built outside the U.S. generally can’t get the FCC authorization needed to import, market, or sell them here, unless they qualify for a Conditional Approval or meet a U.S.-sourcing threshold.
Fresh has spent years designing and building custom robotics domestically, with U.S.-owned IP and full visibility into sourcing. We help you figure out the real path forward, not guesswork.
Ready to get started?
Tell us about your project or current challenges. We'll help you define and adopt a strategic path forward.

Covered List screening & ARD classification
Determine whether current or planned products meet the FCC’s definition of an advanced robotic device, connected power inverter, or related covered technology. Fresh can help map exposure across the product portfolio and identify which products are likely:
- In-scope
- Out-of-scope
- Excluded
- In need of deeper regulatory review

BOM & Supply Chain Mapping
Create clarity where compliance, sourcing, and continuity risks exist and where mitigation planning may be required. Fresh engineers build clear technical maps of product exposure across the full bill of materials, including:
- Country of origin
- Sole-source dependencies
- Supplier criticality
- Beneficial ownership
- Manufacturing and test locations
- Contingency options

Firmware, Software & Domestic IP Development
Reduce dependence on foreign-controlled firmware, embedded software, autonomy stacks, command/control paths, data collection services, cloud integrations, or AI/ML model components. Fresh can support:
- Clean-sheet development
- Architecture refactoring
- Source-code ownership strategy
- Documentation
- Validation
- Long-term maintainability

Conditional Approval Package Support
Help prepare the technical and operational evidence needed for Conditional Approval review for DoW or DHS. This includes:
- Evidence organization
- Technical narratives
- Product architecture documentation
- BOM and supply-chain summaries
- Firmware and software provenance
- Risk gaps
- Contingency plans
- Executive-ready submission materials

Compliant Product Development & Migration
Translate regulatory requirements into practical engineering roadmaps. Fresh can define:
- Architecture changes
- Trusted-supplier substitutions
- Firmware and software migration plans
- Cybersecurity controls
- Verification plans
- Phased transition strategies for current or next-generation products

U.S. Manufacturing & Onshoring Planning
Develop a credible, time-bound roadmap toward domestic end-product status where needed. Fresh can support:
- Assembly strategy
- Supplier qualification
- DFM/DFA
- Pilot builds
- Production test
- End-of-line validation
- Facilities requirements
- Cost/schedule tradeoffs
- Transition planning for U.S.-based manufacturing or final assembly



