Overview
The Federal Communications Commission (FCC) recently announced conditional approval exemptions from the Covered List for companies manufacturing advanced robotic devices.This demonstrates a path forward for manufacturers whose devices may currently be blocked from entering the United States. For companies that are prepared to engage with the conditional approval process, these decisions are encouraging.
In July 2026, the FCC expanded its "Covered List" to include foreign-produced advanced robotic devices, generally preventing new models of robots from obtaining new FCC equipment authorizations needed for US market access. However, manufacturers may seek an exemption through a "conditional approval" process in which the government will evaluate whether the device poses a national security risk. Applicants must provide detailed information about their ownership, supply chains, and manufacturing operations, along with a US onshoring plan. If approved, the equipment is exempted from the Covered List.
The FCC announced two conditional approvals (following a determination by the Department of War) in the advanced robotic device category:
- Husqvarna AB, a Swedish manufacturer of robotic smart lawn mowers (granted September 9, 2026)
- ANSCER Robotics, an Indian manufacturer of Autonomous Mobile Robots (AMRs) primarily used to transport goods in warehouses and factories (granted September 18, 2026).
Both approvals include several product types within a given "robotic platform," providing a basis for companies to seek approval covering related models and configurations. Further, neither approval has an expiration date. As stated in the September 18 Public Notice, "for the Robotic Devices Conditional Approvals that do not reflect termination dates, such Conditional Approvals will remain effective indefinitely, so long as the entity that received Conditional Approval abides by the onshoring plan outlined in its Conditional Approval application and pursuant to updated vetting of the products."
For robotics manufacturers, these grants show that having a credible US onshoring plan, together with satisfaction of other conditional approval requirements, can be a viable path forward to getting products into the US market which may currently be blocked by the Covered List. Steptoe's Telecom and International Trade attorneys can help steer companies that have an affected advanced robotic device through the conditional approval process.
