Navigating the FCC Robotics Restrictions

Mobile, ground-based robots—including autonomous mobile robots, humanoids, and quadrupeds—that operate away from a human operator, weigh over 4.4 lbs combined with any dock or ground station, and include a sensor, network connectivity, and software controlling navigation, perception, or remote command. Fixed industrial arms (SCARA, Cartesian, articulated) are excluded.

National security agencies determined that foreign-produced robots pose supply chain and cybersecurity risks—including the potential for remote data collection, surveillance, or remote commandeering—that outweigh the benefit of continued market access.

The rule is based on production location, not company nationality or ownership. A U.S.-headquartered company can still be affected if its devices are manufactured abroad, and a foreign-headquartered company with true U.S. final assembly may qualify for an exemption.

Under the Buy American Act (48 CFR §25.101(a)), a domestic end product must be manufactured in the U.S. with more than 65% of component cost from U.S. sources through 2028 (rising to 75% in 2029). Devices meeting this threshold fall outside the FCC's "foreign-produced" definition.

The FCC's determination specifically targets mobile, networked, sensor-equipped devices capable of operating away from a human operator—the characteristics tied to the data-collection and remote-access risks cited in the national security determination. Fixed, non-mobile industrial robots don't present the same risk profile and are explicitly excluded.

Manufacturers can apply to the Department of War for a Conditional Approval, providing detailed disclosure of corporate ownership, supply chain, manufacturing locations, and a time-bound U.S. onshoring plan. Approval isn't guaranteed, and applications are due by January 1, 2028.

Conditional Approval depends on an individualized government risk determination with no fixed timeline or guarantee. Meeting the domestic end product threshold is a defined, verifiable standard a company controls directly, which is why many teams treat onshoring as the longer-term strategy even if they also pursue Conditional Approval in the near term.

The restriction is forward-looking. Previously authorized devices can continue to be sold, imported, and used, and software or firmware updates for those devices remain permitted under a separate FCC waiver through at least January 1, 2029.

Supply chain and manufacturing changes—sourcing new component vendors, shifting final assembly, or preparing a Conditional Approval application—take months to years to execute. Companies that start now have more runway than those who wait for a compliance deadline to force the decision.

"Foreign-produced" refers to where a device is manufactured, not who owns or controls the company making it. A U.S.-owned company manufacturing abroad is still foreign-produced; a foreign-owned company with genuine U.S. final assembly meeting the domestic content threshold is not.

Fresh reviews a device's full bill of materials for country-of-origin transparency, flagging single-source dependencies and foreign-sourced components that could jeopardize domestic end product status or complicate a Conditional Approval application.

Retrofitting a foreign-produced platform to meet U.S. content thresholds after the fact is often more expensive and less reliable than designing for domestic sourcing from the start. Additionally, it doesn't resolve questions about existing firmware, IP ownership, or software provenance that also factor into risk assessments.