The US Federal Communications Commission's July 28 expansion of the Covered List to include foreign-produced "advanced robotic devices" is now working its way through supply chains, and the September commentary from Sidley Austin, Forbes and Humanoid Guide makes clear how disruptive the rule will be for buyers of Chinese humanoid and quadruped platforms. The rule blocks new device models above defined thresholds for mobility and sensor density from getting FCC equipment authorisation, effectively shutting new imports out of the US market unless the manufacturer secures a Department of War conditional approval.
What is in scope
The Covered List addition applies to advanced mobile robots including humanoids, quadrupeds, warehouse autonomous mobile robots, sidewalk delivery robots and inspection quadrupeds. It also covers connected power inverters. Existing device models that already hold FCC authorisation can continue to be imported, sold and used – so a US warehouse running AgiBot A3 platforms today is not required to remove them. But every next-generation revision, and every new SKU, must clear the Covered List or the conditional-approval path.
The conditional-approval path
Manufacturers can apply to the Department of War for a "Conditional Approval" exemption that would let them continue receiving FCC equipment authorisation for new models. Applications must be filed before January 1, 2028, and are decided on a case-by-case basis considering ownership structure, data flows and supply-chain provenance. Industry lawyers expect the bar to be high enough that most Chinese-headquartered vendors will need to spin out US-controlled subsidiaries or license technology to US partners.
Immediate ripple effects
China holds roughly 85% of the global humanoid robot market, so the rule reshuffles the US import landscape overnight. Unitree, Galbot, XPENG and AgiBot now face a fork: license their platforms to a US partner, stand up domestic assembly, or accept that new model launches will not reach US customers legally. US-headquartered vendors including Apptronik, Agility Robotics and Boston Dynamics benefit at the margin – as do European players such as NEURA if they can demonstrate no covered-country ownership.
Why it matters
Coming right as global humanoid robot shipments hit 19,100 units in H1 2026 – up 272% year on year – the rule reshapes procurement conversations already underway inside Caterpillar, Amazon and every US defence integrator. Expect a wave of US assembly announcements from Chinese vendors and a matching wave of new US-headquartered joint ventures over the next quarter, alongside continued lobbying from AMR customers who quietly rely on Chinese hardware.
Reporting based on the FCC Covered List fact sheet, Sidley Austin's client alert, Forbes, Quartz and Humanoid Guide.