The Federal Communications Commission’s (“FCC”) Covered List has evolved significantly over the past year. What began largely as an entity-focused regime covering equipment and services associated with specifically identified telecommunications, video-surveillance, and cybersecurity providers is increasingly becoming a broader product-, component-, and production-location-based market-access regime.

That shift deserves attention from companies across the Asia-Pacific region—not only Chinese companies.

Recent FCC actions have extended Covered List treatment to categories including foreign-produced uncrewed aircraft systems (“UAS”), certain UAS critical components, consumer-grade routers, power inverters, and advanced robotic devices. At the same time, the FCC has tightened its equipment-authorization rules, begun addressing previously authorized products, and proposed additional measures concerning components, software, firmware, bills of materials, white-label products, and supply-chain transparency.

For manufacturers selling connected products into the United States, FCC compliance is therefore becoming increasingly intertwined with supply-chain design.

Key Takeaways

• The Covered List is no longer principally an entity-screening exercise. Certain restrictions now apply based on product category and foreign production, potentially affecting manufacturers throughout Asia.

• Moving assembly or changing the brand may not solve the issue. The FCC is increasingly examining components, production activities, technology relationships, software, and the substance of the supply chain.

• FCC review should move upstream into product design and sourcing. Companies should assess Covered List exposure before locking in suppliers, components, manufacturing locations, or U.S. launch plans.

From Named Companies to Product Categories

Historically, much of the attention surrounding the FCC Covered List focused on specifically identified companies.

The initial Covered List included telecommunications and video-surveillance equipment or services associated with companies such as Huawei, ZTE, Hytera, Hikvision, and Dahua, subject to the particular scope specified for each listing. The FCC subsequently added certain Kaspersky products and services and certain telecommunications services offered by specified providers.[1]

That structure made the compliance exercise relatively familiar: identify the relevant listed entity, determine whether the product or service fell within the scope of the listing, and assess the resulting FCC consequences.

Recent developments are materially different.

In December 2025, the FCC added UAS and UAS critical components produced in foreign countries to the Covered List, subject to specified exemptions and the possibility of Conditional Approval. The FCC also added communications and video-surveillance equipment and services identified under Section 1709 of the FY2025 National Defense Authorization Act.[2]

The expansion continued in 2026.

In March, the FCC added certain routers produced in a foreign country to the Covered List. For purposes of that determination, “routers” generally refers to consumer-grade networking devices primarily intended for residential use and capable of customer installation.[3]

In July, the FCC added foreign-produced power inverters and advanced robotic devices, again subject to specified exceptions and Conditional Approval procedures.[4]

The significance of this evolution is difficult to miss: in several important sectors, the threshold question is no longer simply “Who made the product?” It may also be “Where was it produced, what type of product is it, and what is inside it?”

Why This Matters Beyond China

For Asia-Pacific companies, one of the most important points is that several of the recent FCC determinations are expressly not limited to Chinese producers.

The March 2026 router determination applies to routers produced in a foreign country, regardless of the nationality of the producer, unless the relevant equipment receives an applicable Conditional Approval.[3]

This means that production in Taiwan, Vietnam, Malaysia, South Korea, Japan, Thailand, or another non-U.S. jurisdiction may raise the same threshold Covered List issue for products falling within the relevant category.

Indeed, the FCC's published Conditional Approval information already illustrates the breadth of the issue. Companies and products associated with a range of jurisdictions have sought and received approvals for particular routers and other covered devices.[5]

This represents an important compliance shift.

A company can no longer assume that FCC supply-chain restrictions are relevant only if it deals with a specifically named Chinese telecommunications company. For some product categories, a manufacturer that has no connection to any historically listed company may still need to address the Covered List simply because of the location and structure of production.

“Produced in a Foreign Country” May Be Broader Than Final Assembly

Manufacturers should also be cautious about treating final assembly as the only relevant production activity.

In its national-security determination concerning routers, the Executive Branch stated that production generally includes major stages through which a device is made, including manufacturing, assembly, design, and development.[3]

This has potentially significant implications for Asia-Pacific supply chains.

Consider a product that is designed in Taiwan, uses semiconductor and connectivity modules supplied from several Asian jurisdictions, has firmware developed by another affiliate, is assembled in Vietnam, and is sold under a U.S. customer's brand.

A traditional country-of-origin analysis might focus heavily on the location of final manufacturing or substantial transformation.

The FCC inquiry may be different.

For Covered List purposes, companies may need to understand the role played by design, development, assembly, software, firmware, components, intellectual-property ownership, and the entities participating in those activities.

This is one reason FCC compliance should not automatically be assigned to the same team responsible for customs country-of-origin determinations. The two analyses may overlap, but they serve different regulatory purposes and may apply different concepts.

The Conditional Approval Process Is Becoming Important

The recent product-category listings are not necessarily absolute prohibitions.

For routers, UAS, power inverters, and certain other products, the U.S. government has developed Conditional Approval mechanisms through which specified products or classes of products may be exempted from Covered List restrictions following a review.

For manufacturers, however, this should not be viewed as a routine certification process.

The router Conditional Approval guidance illustrates the depth of information that may be required. Applicants may need to disclose matters including:

• complete corporate and ownership structures;

• beneficial owners holding specified ownership interests;

• directors and senior management;

• manufacturing and assembly locations;

• detailed bills of materials;

• country of origin of components;

• software and firmware origins;

• entities responsible for intellectual property and software updates;

• supply-chain concentration by country;

• sole-source suppliers and other potential supply-chain vulnerabilities; and

• plans for establishing or expanding U.S. manufacturing capacity.[3]

The process therefore looks less like conventional FCC radio-frequency testing and more like a supply-chain and corporate-risk assessment.

For Asia-Pacific manufacturers, this has two implications.

First, companies considering Conditional Approval should begin assembling supply-chain information well before the intended U.S. product launch.

Second, the information may require coordination among engineering, procurement, legal, export-control, cybersecurity, corporate-secretarial, and senior-management functions. No single compliance team is likely to possess all of it.

Components Are Becoming More Important

A second major development is the FCC's increasing focus below the finished-product level.

In July 2026, the FCC adopted its Third Report and Order addressing the equipment-authorization program. Among other measures, the order closes what the FCC described as a “component part loophole.”

Under the new framework, authorization may be prohibited for certain devices incorporating logic-bearing hardware components produced by an entity identified on the Covered List where the finished device would have been prohibited if the Covered List entity had produced the device itself.[6]

That matters particularly for Asian electronics manufacturing, where components, modules, chipsets, controllers, communications modules, and other logic-bearing parts frequently move through highly integrated cross-border supply chains.

The practical compliance question may therefore no longer stop at:

Who manufactures the finished product?

Companies may also need to ask:

Who produces the relevant logic-bearing components inside it?

This could be particularly important for OEMs and ODMs that purchase modules or electronic assemblies from third parties without historically screening those suppliers against FCC-specific restrictions.

More May Be Coming: Software, Firmware, HBOMs and SBOMs

The FCC has also proposed additional changes that are not yet final and should therefore be distinguished from existing requirements.

In its accompanying Third Further Notice of Proposed Rulemaking, the FCC sought comment on measures that could further extend supply-chain transparency requirements.

Among other things, the FCC is considering:

• broader restrictions involving Covered List hardware components;

• potential treatment of software and firmware produced by Covered List entities;

• hardware bills of materials (“HBOMs”);

• software bills of materials (“SBOMs”);

• component-origin reporting;

• additional measures addressing white labeling and electrically identical devices;

• further restrictions involving importation and marketing;

• time limits on equipment authorizations;

• registration requirements for certain SDoC devices; and

• a potential requirement for a U.S.-based liable party for FCC-certified equipment.[7]

These remain proposals rather than final rules.

Nevertheless, they provide useful direction for compliance planning. They suggest that the FCC's equipment-authorization program may increasingly require visibility not just into the final product manufacturer, but into the architecture of the product and its underlying supply chain.

For companies developing products with multi-year life cycles, waiting until these issues become final requirements may be commercially difficult. Some degree of forward-looking supply-chain mapping may therefore be prudent.

White Labeling and Contract Manufacturing Require Particular Care

The FCC's recent activity also deserves attention from companies using white-label, licensing, contract-manufacturing, or technology-sharing structures.

An August 2026 FCC proceeding concerning certain previously authorized UAS is instructive.

The FCC examined products sold by a U.S.-based drone company and considered, among other factors, publicly reported technology-sharing or licensing relationships as well as the location of production. The FCC noted that the relevant UAS and controllers were produced in Malaysia and initiated proceedings concerning whether continued importation and marketing of certain previously authorized products should be prohibited.[8]

The proceeding remains important not because every licensing arrangement will produce the same result, but because it demonstrates the type of inquiry manufacturers should expect.

Changing the label on a product, moving final assembly to a different country, inserting an intermediary company, or selling through a U.S. brand does not necessarily end the analysis.

Companies may need to examine the underlying relationships among:

technology – design – manufacturing – licensing – components – software – branding – ownership.

For Chinese manufacturers expanding production into Southeast Asia, this is particularly relevant. Moving production from China to Vietnam or Malaysia may have important commercial and customs consequences, but it should not automatically be assumed to remove FCC Covered List exposure.

The same principle applies to non-Chinese Asian manufacturers licensing technology from, or sharing production platforms with, another company that may itself present Covered List concerns.

Existing FCC Authorizations Are No Longer Necessarily the End of the Story

Another notable development concerns products that received FCC authorization before becoming covered equipment.

Historically, companies could reasonably focus on whether a product had already obtained its FCC equipment authorization.

That assumption is becoming less secure.

In 2025, the FCC established procedures permitting it, under specified circumstances, to restrict the continued importation and marketing of previously authorized covered equipment without necessarily prohibiting continued use of products already purchased.

In 2026, the FCC began using that authority. Restrictions on continued importation and marketing of certain previously authorized covered communications equipment added to the Covered List in 2024 or earlier became effective in July 2026.[9]

The FCC has also opened additional proceedings concerning certain previously authorized UAS and other equipment added to the Covered List later.[8]

This creates a new product-life-cycle issue.

For manufacturers, distributors, U.S. importers, and retailers, obtaining an FCC ID can no longer always be treated as the final regulatory event for a product.

Companies may need to monitor:

• subsequent Covered List additions;

• changes in the scope of existing listings;

• changes to Conditional Approvals;

• FCC limitations on existing equipment authorizations; and

• restrictions on continued importation or marketing.

In practical terms, FCC compliance is becoming more dynamic.

The FCC Is Also Tightening the Authorization Ecosystem

The changes extend beyond manufacturers themselves.

In September 2026, the FCC published a consolidated Prohibited Entities List for purposes of its equipment-authorization integrity rules.[10]

The consolidated list draws from several government lists, including the FCC Covered List and specified Commerce Department and other federal government restrictions.

The purpose is different from the Covered List itself. Among other things, the rules affect the ownership and control of entities participating in the FCC equipment-authorization ecosystem, including testing and accreditation functions.

For Asia-Pacific companies, this development matters because much FCC compliance work occurs outside the United States.

Manufacturers frequently rely on Asian testing laboratories, accreditation bodies, Telecommunications Certification Bodies, engineering consultants, and other third parties. Vendor screening should therefore extend beyond the manufacturer and its component suppliers to include the entities supporting FCC certification.

What Asia-Pacific Manufacturers Should Do Now

The immediate response should not be to assume that every foreign-produced connected device is prohibited. That would overstate the current rules.

The Covered List remains product- and scope-specific. Certain categories contain exceptions, Conditional Approvals may be available, and several of the FCC's most expansive ideas remain proposals rather than final requirements.

But companies selling communications-enabled products into the United States should consider several practical steps.

First, screen products—not only companies.

Traditional restricted-party screening remains necessary, but it is no longer sufficient. Companies should identify whether their product portfolio falls within categories such as routers, UAS and critical components, advanced robotic devices, relevant power inverters, or other Covered List categories.

Second, map the relevant supply chain.

For potentially affected products, companies should understand who performs design, development, manufacturing, assembly, software and firmware development, and production of significant logic-bearing components.

Third, inventory FCC authorizations.

Manufacturers should know which products rely on certification, SDoC, modular authorization, or another FCC pathway; who holds the FCC ID; and whether any previously authorized products could become affected by a later Covered List development.

Fourth, review OEM, ODM, licensing, and white-label arrangements.

Contracts should provide sufficient information rights to determine who actually designs and produces the product and its important components. Representations limited to the identity of the immediate supplier may increasingly be inadequate.

Fifth, consider Conditional Approval early.

Where a product falls within a foreign-production category, companies should determine well before launch whether Conditional Approval is necessary and commercially realistic.

A Broader Shift in U.S. Market-Access Compliance

The most important development may ultimately be conceptual.

FCC equipment authorization was traditionally viewed primarily as a technical regulatory exercise: test the radio-frequency device, demonstrate conformity, obtain the required authorization, label the product correctly, and proceed to market.

That model is changing.

For a growing number of products, FCC market access now intersects with questions involving corporate ownership, production geography, component sourcing, cybersecurity, software and firmware, supply-chain resilience, technology relationships, and manufacturing strategy.

That makes the recent Covered List developments particularly important for Asia-Pacific manufacturers.

The question is increasingly not simply whether the finished product complies with FCC technical standards.

It is also:

who designed it, who produced it, what is inside it, where those activities occurred, and whether the company can demonstrate sufficient visibility into that supply chain.

For manufacturers supplying the U.S. market, those questions are increasingly becoming part of product compliance itself.

Notes

[1] Federal Communications Commission, List of Equipment and Services Covered by Section 2 of the Secure Networks Act; Secure and Trusted Communications Networks Act of 2019, 47 U.S.C. §§ 1601–1609.

[2] FCC Public Safety and Homeland Security Bureau, Addition of Uncrewed Aircraft Systems (UAS) and UAS Critical Components Produced Abroad, and Equipment and Services Listed in Section 1709 of the FY2025 NDAA, to FCC Covered List, DA 25-1086, Dec. 22, 2025; subsequent exemptions and updates issued Jan. 7, June 15, and July 21, 2026.

[3] FCC Public Safety and Homeland Security Bureau, Addition of Routers Produced in Foreign Countries to FCC Covered List, DA 26-278, Mar. 23, 2026, including the attached National Security Determination and Conditional Approval Guidance.

[4] FCC Public Safety and Homeland Security Bureau, Addition of Foreign-Produced Power Inverters and Advanced Robotic Devices to FCC Covered List, DA 26-786, July 28, 2026; Modification of Power Inverters Entry on the Covered List, DA 26-870, Aug. 20, 2026.

[5] FCC Public Safety and Homeland Security Bureau, Conditional Approval and Exemption of Certain Routers and Advanced Robotic Devices from FCC Covered List, DA 26-957, Sept. 9, 2026. The published approvals include products associated with a range of manufacturers and jurisdictions.

[6] FCC, Protecting Against National Security Threats to the Communications Supply Chain through the Equipment Authorization Program, Third Report and Order, FCC 26-50, adopted July 22 and released July 23, 2026.

[7] FCC, Third Further Notice of Proposed Rulemaking, ET Docket No. 21-232, FCC 26-50, July 2026. These matters remain proposals unless and until separately adopted by the Commission.

[8] FCC Public Safety and Homeland Security Bureau and Office of Engineering and Technology, Prohibiting the Importation and Marketing of Certain Covered UAS and UAS Critical Components and Equipment Listed in Section 1709 of FY2025 NDAA, DA 26-832, Aug. 10, 2026.

[9] FCC Public Safety and Homeland Security Bureau and Office of Engineering and Technology, Prohibiting the Importation and Marketing of Previously Authorized Covered Communications Equipment Added to the Covered List in 2024 or Earlier, DA 26-635, June 26, 2026; restrictions effective July 16, 2026.

[10] FCC, FCC Publishes Consolidated Prohibited Entities List to Support Equipment Authorization Integrity, DA 26-962, Sept. 9, 2026.

This article reflects developments through September 15, 2026 and is intended for general informational purposes only.