President Trump, Chairman Carr, and the Department of War have officially recognized that connected robots are not simply another category of consumer electronics. Last week, the FCC added foreign-produced network-connected mobile robots to the Covered List, effectively banning their commercial sale in the U.S. This is primarily a national-security action protecting Americans and critical infrastructure, but we would be remiss to ignore its force as industrial policy which creates opportunities for American robot manufacturers.
The U.S. has acted before foreign robotic platforms become as deeply embedded in American homes and factories as foreign telecoms equipment became in communications networks. The result is a protected commercial market in which American manufacturers can finally compete to build secure, affordable, and open robot platforms.
What the FCC’s “robot ban” actually does
The definition of “advanced robotic devices” practically encompasses all network-connected mobile robots. This includes humanoids, quadrupeds, warehouse platforms, articulated arms with mobile bases, delivery robots, autonomous forklifts, and robot vacuums. Conventional stationary arms remain outside the robotics determination. Despite initial online concern, the accompanying power inverter action does not sweep ordinary robot controllers into the Covered List.
Every electronic device that emits a radio frequency requires FCC authorization before it can be marketed, sold, or imported in the U.S. Ordinarily, this is just a routine technical certification. But items on the Covered List are categorically ineligible for authorization.
Any previously authorized robot model is unaffected, provided that no hardware modifications are made. This means that Chinese robots such as the Unitree G1 (the dominant humanoid research platform) and current-gen Roombas can still be sold in the U.S. Furthermore, certain producers can be granted Conditional Approval, which permits a new foreign-produced device or class to obtain FCC authorization despite its status on the covered list. Precedent favors company-specific approvals covering particular models or classes of products.
What qualifies as “foreign-produced?”
The Covered List restricts foreign-produced models rather than models produced by foreign entities. Therefore, an American company manufacturing abroad may be covered while a foreign-owned company that manufactures in America will not be.
The manufacturing requirements differ substantially between models based on their classification as commercial-off-the-shelf (COTS) products. Non-COTS models are held to the Federal Acquisition Regulation’s “Buy American Standard:” they must be assembled in the U.S. and at least 65 percent of their components by cost must be sourced domestically. But COTS models are held to a much lower standard: only U.S. assembly is required to avoid classification as a foreign produced model. Superficial final assembly (screwdriver assembly) should not qualify.
This could be problematic for American startups. A standardized foreign-designed robot that is assembled substantially in America may qualify as COTS, while an early-stage American humanoid built in small quantities may be non-COTS and therefore face the stricter component test. To avoid this, the FCC and Department of War should consider the following actions:
- Quickly clarify what constitutes U.S. manufacture for major robot categories to create certainty for U.S. manufacturers and prevent foreign manufacturers from establishing screwdriver plants in the U.S.
- Be flexible with COTS designations in the near term. At present, there is no body which determines whether a product qualifies as COTS for the purposes of import controls.
- Favor non-COTS American manufacturers for Conditional Approval when they use secure allied components.
This action was both timely and necessary
As with all additions to the Covered List, last week’s rule change was accompanied by a National Security Determination. The Determination itself presents a strong security case for the decision. Robots combine three security-relevant properties: persistent sensing of homes, factories, warehouses, and critical infrastructure; capacity to receive networked commands or updates; and the ability to move through and (sometimes) manipulate the physical world.
The combination of these properties creates several vulnerabilities, including data exfiltration, withholding updates, remote deactivation, and commandeering robots to engage in kinetic attacks against critical infrastructure or even American citizens. Therefore, data localization rules are not sufficient. Requiring data to be kept in the United States addresses only telemetry risks, and only insofar as we can ensure that there is no covert channel back to the manufacturer.
Humanoids and quadrupeds present the strongest case for these restrictions. As autonomy improves, these robots will be able to move through any environment designed for people, collect an array of high-fidelity sensory input, and operate tools or industrial equipment. Continuing to import foreign-controlled, high-autonomy mobile manipulators could become akin to importing foreign soldiers and deploying them in American homes and factories.
At present, American researchers and startups overwhelmingly rely on Chinese Unitree robots because they are the only commercially available humanoids with an open development platform. An American company cannot rationally invest in becoming the low-cost, open hardware platform while competing against subsidized Chinese production, cheap labor, and the dense hardware ecosystem of Shenzhen.
Continued unrestricted market access entrenches the foreign platform, developer ecosystem, spare-parts network, and data advantage. Market certainty changes the investment calculation. Preventing Chinese Unitree models from scaling commercially creates the demand needed for an “American Unitree.” The Covered List’s application to all foreign production shows that it is more ambitious than China de-risking, suggesting that the Department of War had industrial policy in mind when scoping this rule.
The FCC is not acting too early. Similar action against high-autonomy mobile foreign robots would be inevitable once the risks were realized. Acting early means the costs are minimized, because American industry has certainty and can start building the necessary domestic supply chains during the technology’s infancy. Acting now is far cheaper than replacing millions of entrenched robots later.
How will this affect research access?
The decision was met with backlash from many in the robotics industry, including prominent robotics researchers, investors, and industry commentators. Much of the criticism is based in concerns about disruption to research that currently relies on Unitree humanoids. But these concerns are unfounded—if anything, the current rule is far too lenient on imports for research use!
As it stands, a company or research institution can import up to 4,000 units for genuine testing, evaluation, or product development. This is assessed per model, so separate generations count separately and larger quantities may receive written approval from the FCC’s Office of Engineering and Technology. This allows for the continued training of robot policies using new Chinese robot models, as well as hardware teardowns.
Given that the majority of American demand for foreign humanoid robots comes from researchers, the addition of connected mobile robots to the Covered List will likely have a minimal effect on demand for the next generation of Unitree platforms. The FCC has proposed that the cap be reduced to 40 units. This is a defensible allowance for covered advanced robots, and would further incentivize the American robotics industry to build the Unitree competitor we need.
American researchers can continue making progress on robot software and humanoid motion control using foreign robot bodies. Foreign hardware producers lose the ability to scale new models commercially, and this decision credibly signals to domestic producers that hardware-first humanoid startups that invest in open development platforms are viable.
Secure robots, built in America
Connected robots carry both telemetry and remote control risks, and this is particularly true for high-autonomy mobile robots. Dependence on foreign platforms also prevents the emergence of an independent American robotics industry.
President Trump and the FCC have rightly taken action before costs grow too high and entrenched interests gain the ability to shape policy toward continued dependence. Many of the concerns raised by critics are either unfounded or can be resolved in implementation.
The FCC’s action creates the market certainty American manufacturers need to build secure, affordable robotic systems at home. The next generation of humanoid robots will be manufactured in America, secure against foreign control.
