FCC equipment authorization + Covered ListFCCConditional
before-entry
Devices with RF functions need an FCC ID (Certification) or SDoC before import / marketing (for foreign manufacturers the U.S. importer is the responsible party). Covered List equipment cannot be authorized. Form 740 was eliminated on 2017-11-02.
2025–26: "Bad labs" rule FCC 25-27 (effective 2025-09-08, 10% ownership threshold, 15 Chinese labs de-recognized); FCC 25-71 (effective 2025-12-26): a covered modular transmitter makes the host device covered too; 2025-12-22 DA 25-1086 added all foreign-produced UAS and critical components to the Covered List (DA 26-22: Blue UAS / >65% U.S. content exempt until 2027-01-01; no exemption for DJI / Autel); 2026-03-23 DA 26-278 added foreign-produced consumer routers (some models conditionally approved, DA 26-585); 2026-06-26 DA 26-635 (effective 2026-07-16): previously authorized Huawei / ZTE / Kaspersky equipment may no longer be imported or sold; 2026-07-28 DA 26-786 added foreign-produced grid-tied inverters and advanced robots (DA 26-870 on 2026-08-20 narrowed inverters to UL 1741 grid-tied inverters with or capable of a communications module; §45X / 48 CFR 25.101 compliant products exempt; software-update waiver DA 26-789 until 2029-01-01); FCC 26-50 (91 FR 57798, effective 2026-10-13): equipment containing "logic components" from Covered List companies cannot be authorized, and e-commerce platforms must display the FCC ID (compliance 2027-03-01 / 06-01)
Basis: 47 CFR Part 2 Subpart J/K; 47 U.S.C. 1601–09Scope: 8525 (Determined by product attributes (the HTS code is only a hint))Exemptions: §2.1204 exceptions: ≤4,000 units for testing, ≤400 for trade shows, 3 for personal use, 12,000 for pre-sale, etc.CSMS / source: FCC OET importation; FCC 25-27; FCC 25-71; DA 25-1086; DA 26-22; DA 26-278; DA 26-635; DA 26-786; DA 26-870; FCC 26-50 (91 FR 57798)Verification: H (Covered List entries in fcc-covered-list.csv; fcc.gov returns 403 to cloud access, so the Public Notices / FR text are the reference) FCC Covered List (47 CFR 1.50002 / 2.903) · hits 6 · rules 6
CL-2021-01 · Huawei Technologies Company (incl. subsidiaries and affiliates; FCC-listed associated entities include Huawei Technologies USA Inc., Huawei Technologies Co. Ltd., Huawei Device Co. Ltd.; HiSilicon is a Huawei subsidiary [S])8525.89Conditional
added 2021-03-12
No new FCC equipment authorization (certification or SDoC) since 2023-02-06 (47 CFR 2.903); equipment otherwise exempt from authorization also barred (2.903(c)(3)). Previously authorized models: continued importation and marketing PROHIBITED since 2026-07-16 (DA 26-635 under 47 CFR 2.939(e)). Import requires a valid, un-limited authorization or a 2.1204 condition; FCC states covered equipment "could not be imported or marketed" (FCC 26-50). | By producer (check the manufacturer / brand and its affiliates)
Exemptions: None for new authorizations. Consumer continued use only. Do not rely on 2.1204(a)(3) testing (4,000 units), (a)(4) trade show (400), (a)(7) personal use (3) or (a)(11) pre-sale (12,000) conditions for covered equipment: 2.903(c)(3) extends the prohibition to equipment exempt from authorization and FCC 26-50 revised 2.1204(a)(2) to require compliance with FCC "administrative" regulations (TBD_ no FCC KDB expressly addresses (a)(3) for covered equipment).
Equipment: Verbatim: "Telecommunications equipment produced or provided by Huawei Technologies Company, including telecommunications or video surveillance services produced or provided by such entity or using such equipment." Footnote: applies only to equipment/services capable of the functions in Secure Networks Act sec. 2(b)(2)(A)-(C). "Produced by" = substantial responsibility for or control over design, development, manufacture or assembly (FCC 25-71). Covered modular transmitters (2.903(a)(1)-(2)) and, from 2026-10-13, logic-bearing hardware components (e.g., Huawei/HiSilicon SoCs) taint any host device (2.903(b)).Existing authorizations: FCC 22-84 did NOT revoke pre-2022-11-11 grants (Secure Equipment Act sec. 2(a)(3)(A)). BUT DA 26-635 (91 FR 41023) limited all pre-existing authorizations of equipment added to the Covered List in 2024 or earlier: importation and marketing prohibited from 2026-07-16; consumer use of lawfully purchased devices continues. No permissive changes/modifications allowed (2.932(f), 2.1043(b) as amended by FCC 25-71/26-50); spare-parts/replacement exemption expressly rejected.CSMS / source: DA 21-309 (2021-03-12); FCC 22-84 (adopted 2022-11-11, released 2022-11-25; 88 FR 7592, eff. 2023-02-06); DA 25-927 National Security Advisory 2025-01 (2025-10-14, affiliate list); DA 26-635 (2026-06-26; 91 FR 41023, eff. 2026-07-16) CL-2021-03 · Hytera Communications Corporation (incl. subsidiaries and affiliates; FCC-listed associated entities: Hytera US Inc, Teltronic S.A. Unipersonal, Norsat International Inc., HMF Smart Solutions GmbH)8525.89Conditional
added 2021-03-12
No new FCC equipment authorization of any Hytera telecom or video-surveillance equipment since 2023-02-06 (conditional/use-based prohibition applied as a full freeze pending an FCC-approved plan). Previously authorized models: since 2026-07-16 importation/marketing prohibited ONLY to the extent the equipment is for the enumerated purposes (public safety, government-facility security, other national security); the "physical security surveillance of critical infrastructure" prong of the import/marketing ban is SUSPENDED until the FCC adopts a critical-infrastructure definition (FCC 26-50 codified one in 47 CFR 1.50001 effective 2026-10-13 — lifting of suspension TBD_). | By producer (check the manufacturer / brand and its affiliates)
Exemptions: Importer may continue to import previously authorized models for non-enumerated uses (must document end use); no exemption for new authorizations. D.C. Circuit (Hikvision USA v. FCC, 2024-04-02) upheld the freeze but vacated the prior "critical infrastructure" definition.
Equipment: Verbatim: "Video surveillance and telecommunications equipment produced or provided by Hytera Communications Corporation, to the extent it is used for the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, including telecommunications or video surveillance services produced or provided by such entity or using such equipment." FCC 22-84 treatment: because the use-based scope cannot be policed at authorization stage, ALL new authorizations of Hytera telecom/video-surveillance equipment are prohibited until the FCC approves a Hytera plan ensuring the equipment is not marketed/sold for those purposes (interim freeze from 2022-11; no plan approved as of 2026-09-14 [S]).Existing authorizations: Pre-rule grants not revoked by FCC 22-84. DA 26-635 limits prior authorizations only for the enumerated uses (critical-infrastructure prong suspended). Non-covered uses (e.g., consumer/commercial radios not for those purposes) may continue to be imported/marketed under existing FCC IDs [S]; no new models, no permissive changes.CSMS / source: DA 21-309; FCC 22-84 (88 FR 7592); DA 25-927; DA 26-635 (91 FR 41023); FCC 26-50 (91 FR 57798, 1.50001 definition eff. 2026-10-13) CL-2021-04 · Hangzhou Hikvision Digital Technology Company (incl. subsidiaries and affiliates; FCC-listed associated entities: Hikvision USA Inc., Hangzhou Ezviz Network Co. Ltd., Hangzhou EZVIZ Software Co. Ltd., Hangzhou Hikrobot Co. Ltd., Hangzhou Hikmicro Sensing Technology Co. Ltd., Hangzhou Rayin Technology Co. Ltd., Hangzhou Hikauto Technology Co. Ltd., Wuhan Hikstorage Technology Co. Ltd., Hangzhou Hikstorage Technology Co. Ltd.)8525.89Conditional
added 2021-03-12
No new FCC equipment authorization of any Hikvision (or affiliate) telecom/video-surveillance equipment since 2023-02-06 (freeze pending plan). Previously authorized models: since 2026-07-16 importation/marketing prohibited to the extent for public safety, government-facility security or other national security purposes; the critical-infrastructure prong of that import/marketing ban is suspended until the FCC's definition takes effect (FCC 26-50, 47 CFR 1.50001, eff. 2026-10-13 — TBD_ whether the Bureaus lift the suspension). Note also NDAA sec. 889 federal procurement ban (separate). | By producer (check the manufacturer / brand and its affiliates)
Exemptions: Import of previously authorized models for non-enumerated uses (document end use). No exemption for new authorizations. Devices exempt from authorization are also barred (2.903(c)(3)).
Equipment: Verbatim: "Video surveillance and telecommunications equipment produced or provided by Hangzhou Hikvision Digital Technology Company, to the extent it is used for the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, including telecommunications or video surveillance services produced or provided by such entity or using such equipment." FCC 22-84: full freeze on new authorizations pending FCC approval of a Hikvision plan (none approved as of 2026-09-14 [S]). Includes affiliate brands (EZVIZ consumer cameras, Hikrobot, Hikmicro thermal, Hikstorage). White-label/OEM cameras "produced by" Hikvision are covered (FCC 25-71 "produced by" test).Existing authorizations: Not revoked by FCC 22-84; DA 26-635 limits existing authorizations for enumerated uses only (CI prong suspended). Previously authorized models for non-enumerated uses (e.g., residential/retail) may still be imported/marketed under existing FCC IDs [S]; no new models; no permissive changes. FCC 26-7 (2026-02-19) NAL example (Dahua) shows enforcement of 2.903(d) affiliate-disclosure duty.CSMS / source: DA 21-309; FCC 22-84 (88 FR 7592); Hikvision USA Inc. v. FCC (D.C. Cir. 2024-04-02, CI definition vacated); DA 25-927 (affiliates); DA 26-635 (91 FR 41023); FCC 26-50 (91 FR 57798) CL-2021-05 · Dahua Technology Company (Zhejiang Dahua Technology Co., Ltd.; incl. subsidiaries and affiliates — FCC-listed: Zhejiang Dahua Vision Technology Co. Ltd., Hangzhou Huacheng Network Technology Co. Ltd. (IMOU), Zhejiang HuaRay Technology Co. Ltd., plus ~129 further entities in DA 25-927 App. B; Lorex was a Dahua subsidiary until 2023 [S])8525.89Conditional
added 2021-03-12
Same regime as Hikvision: no new authorizations since 2023-02-06; DA 26-635 import/marketing prohibition (from 2026-07-16) on previously authorized models to the extent used for the enumerated purposes (CI prong suspended pending definition). FCC 26-7 (2026-02-19): $188,491 NAL against Zhejiang Dahua for 2.5-year failure to file 2.903(d) affiliate contact information. | By producer (check the manufacturer / brand and its affiliates)
Exemptions: Import of previously authorized models for non-enumerated uses (document end use). No exemption for new authorizations.
Equipment: Verbatim: "Video surveillance and telecommunications equipment produced or provided by Dahua Technology Company, to the extent it is used for the purpose of public safety, security of government facilities, physical security surveillance of critical infrastructure, and other national security purposes, including telecommunications or video surveillance services produced or provided by such entity or using such equipment." FCC 22-84: full freeze on new authorizations pending FCC-approved plan (none approved as of 2026-09-14 [S]).Existing authorizations: Not revoked by FCC 22-84; limited by DA 26-635 for enumerated uses; non-enumerated-use imports of previously authorized models continue [S]; no new models; no permissive changes.CSMS / source: DA 21-309; FCC 22-84 (88 FR 7592); DA 25-927; FCC 26-7 (NAL 2026-02-19); DA 26-635 (91 FR 41023) CL-2025-01 · Uncrewed aircraft systems (UAS) and UAS critical components produced in a foreign country (categorical, all producers) + all equipment listed in FY2025 NDAA sec. 1709(a)(1) (DJI and Autel Robotics and their subsidiaries, affiliates, partners, joint ventures and technology-sharing entities)8525.89Conditional
added 2025-12-22
No new FCC equipment authorization for any foreign-produced UAS or UAS critical component (new models/FCC IDs) since 2025-12-22 (47 CFR 2.903); new devices incorporating covered modular transmitters also barred. Importation of a new-model foreign drone requiring certification is therefore impossible under 2.1204(a)(1). DJI/Autel equipment covered by name via NDAA sec. 1709 regardless of production location. Components that do not themselves require FCC authorization (e.g., bare motors, batteries) are "covered" but the practical FCC consequence attaches at authorization of the UAS/host device (TBD_ FCC has not issued component-level import guidance). | By product category (restricted when produced abroad; check the exemption conditions)
Exemptions: Until 2027-01-01: (a) DCMA Blue UAS Cleared List items; (b) items qualifying as Buy American "domestic end products" (48 CFR 25.101(a): manufactured in U.S. with >65% domestic component cost through 2028, 75% from 2029). Indefinite: DoW/DHS Conditional Approvals (apply via conditional-approvals@fcc.gov; onshoring plan, ownership, BOM). Federal-government purchases unaffected. DJI/Autel excluded from all exemptions [S]. 2.1204(a)(3)-(a)(11) import conditions do not create an authorization.
Equipment: Verbatim entry (DA 25-1086 as revised by DA 26-22): "Uncrewed aircraft systems (UAS) and UAS critical components produced in a foreign country — except, until January 1, 2027, (a) UAS and UAS critical components included on the Defense Contract Management Agency's (DCMA's) Blue UAS Cleared List, and (b) UAS and UAS critical components that qualify as 'domestic end products' under the Buy American Standard, 48 CFR 25.101(a) ... and all communications and video surveillance equipment and services listed in Section 1709(a)(1) of the FY25 National Defense Authorization Act (Pub. L. 118-159)" [ellipsis: exact conjunction TBD_ verify against FCC page]. UAS = 47 CFR 88.5 ("An Uncrewed Aircraft and its associated elements (including an uncrewed aircraft station, communication links, and the components not on board the UA that control the UA)..."). UAS critical components "include but are not limited to": data transmission devices; communications systems; flight controllers; ground control stations and UAS controllers; navigation systems; sensors and cameras; batteries and battery management systems; motors; and associated software. "Produced in a foreign country": any major stage (design, development, manufacture, assembly) outside the U.S.; final-assembly location not determinative (FCC FAQ [S]). Also excepted: UAS/components for which DoW or DHS makes a specific Conditional Approval determination (DA 26-585 lists approvals, e.g., ABZ Innovation L50, SiFly Q12, Mobilicom SkyHopper, ScoutDI Scout 137).Existing authorizations: FCC: "This update to the Covered List does not prohibit the import, sale, or use of any existing device models the FCC previously authorized" (DOC-417528A1 fact sheet). Existing FCC IDs remain valid for import/sale; NOT covered by DA 26-635 (which reaches only 2024-or-earlier entries). No hardware permissive changes; software/firmware Class I & II changes waived by DA 26-69 (2026-01-21, to 2027-01-01) as extended/expanded by DA 26-454 (2026-05-08) through 2029-01-01. FCC reserves authority to limit prior authorizations under 2.939(e) in future.CSMS / source: DA 25-1086 (2025-12-22); DA 26-22 (2026-01-07); DOC-417528A1 fact sheet (2026-01-07); DA 26-69 (2026-01-21); DA 26-454 (2026-05-08); DA 26-585 (2026-06-12 conditional approvals); FY25 NDAA sec. 1709 (Pub. L. 118-159); DJI v. FCC, 9th Cir. No. 26-1029 (pending) CL-2026-04 · Foreign-produced advanced robotic devices (mobile ground robots incl. autonomous mobile robots, humanoids, quadrupeds), except those granted Conditional Approval by DoW8525.89Conditional
added 2026-07-28
No new FCC equipment authorization for foreign-produced advanced robotic devices since 2026-07-28 (47 CFR 2.903) — every Wi-Fi/Bluetooth/cellular-connected mobile robot is an RF device needing certification, so new models cannot be authorized or imported. Conditional Approval: DoW only; applications close 2028-01-01; require BOM, ownership (≥5% beneficial owners), country of origin of design/software, and quantified U.S. onshoring plan with quarterly reports. | By product category (restricted when produced abroad; check the exemption conditions)
Exemptions: Buy American domestic end product (48 CFR 25.101(a), >65%/75% domestic component cost); listed exclusions (connected vehicles, rail, UAS, UUVs, FDA medical devices, fixed industrial/medical robots); devices ≤4.4 lbs or without ≥200 kbps connectivity; DoW Conditional Approval; previously authorized models; federal government use.
Equipment: Verbatim entry: "Foreign-produced advanced robotic devices, except advanced robotic devices which have been granted a Conditional Approval by DoW." Definition (NSD 2026-07-27, as summarized by Wiley/Skadden/Sidley [S] — verbatim appendix TBD_): a mechanical device, including autonomous mobile robots, humanoid robots and quadrupeds, that (1) is capable of locomotion, obstacle avoidance, navigation or movement on the ground; (2) operates at a distance from a human operator/supervisor based on commands or in response to sensor data; (3) weighs more than 4.4 lbs (incl. docking station); and (4) contains an environmental sensor, a network-connectivity component (≥200 kbps) and software controlling autonomous navigation/movement or remote command-and-control (incl. AI/ML weights [S]). Exclusions: connected vehicles (15 CFR 791.301); rail-only vehicles; UAS (47 CFR 88.5); unmanned underwater vehicles; FDA-regulated medical devices (21 U.S.C. 360c) incl. surgical robots, prostheses, mobility-assistive devices; fixed/stationary industrial or medical robots (SCARA, articulating, Cartesian, delta arms). "Foreign-produced" = not a "domestic end product" under 48 CFR 25.101(a). Consumer robots >4.4 lbs with Wi-Fi/LiDAR (robot vacuums, robotic lawn mowers, pool robots, delivery robots) fall within the literal definition — product-specific analysis required [S].Existing authorizations: Previously authorized models remain valid unless later revoked/limited (not within DA 26-635); may continue to be imported/sold; hardware permissive changes prohibited; software/firmware Class I & II changes waived by DA 26-789 through 2029-01-01.CSMS / source: DA 26-786 (2026-07-28; NSD 2026-07-27); DA 26-789 (2026-07-28); DOC-423682A1 (2026-07-28); FCC FAQ page fcc.gov/covered-list-faqs-robots-inverters (inaccessible to fetch — 403) FCC equipment-authorization rules (all RF devices) (6)
- EA-2022-01 47 CFR 2.903 — prohibition on authorization of equipment on the Covered List (Secure Equipment Act of 2021 implementation): Covered equipment cannot obtain certification or SDoC; therefore cannot be legally imported (47 CFR 2.1203/2.1204(a)(1)) or marketed (47 CFR 2.803). Applies to all Covered List entries, present and future, automatically upon listing. — Adopted 2022-11-11; released 2022-11-25; 88 FR 7592 (2023-02-06), effective 2023-02-06 (some PRA-dependent attestation provisions later) · FCC 22-84 (ET Docket 21-232, EA Docket 21-233); 88 FR 7592
- EA-2025-01 "Bad labs" rule — test labs, TCBs and lab accreditation bodies owned/controlled (≥10% equity/voting, or direction/subsidy) by prohibited entities (Covered List entities, BIS Entity List/MEU, DoD 1260H, Treasury NS-CMIC, UFLPA Entity List, NDAA sec. 5949 companies, or foreign adversary governments) barred from the equipment authorization program: Importers must confirm the FCC test lab and TCB on the grant/SDoC file are currently FCC-recognized (OET list); reports from prohibited labs cannot be used for new applications or permissive changes. Previously granted authorizations were not automatically invalidated by FCC 25-27 (TBD_ FCC has not announced mass revocation). — Adopted 2025-05-22; released 2025-05-27; 90 FR 38045 (2025-08-07); effective 2025-09-08 (PRA-dependent parts later) · FCC 25-27 (ET Docket 24-136); 90 FR 38045; DOC-414369A1 (2025-09-08); DOC-414863A1 (2025-09-26); FCC 26-28 (2026-04-30 Second R&O/Order on Recon/Second FNPRM)
- EA-2025-02 Second R&O FCC 25-71 — covered modular transmitters and host devices; "produced by" definition; prohibition on modifications/permissive changes to covered equipment; new 47 CFR 2.939(e) procedure to limit existing authorizations (bar continued import/marketing while allowing use): Any host device (of any brand) that incorporates a Huawei/ZTE (or other covered-entity) radio module cannot be authorized after 2025-12-26; importers must verify module vendor on FCC ID/BOM. Authorizations limited under 2.939(e) no longer satisfy the 2.1204(a)(1) import condition. — Adopted 2025-10-28; released 2025-10-29; 90 FR 53227 (2025-11-25); effective 2025-12-26 · FCC 25-71 (ET Docket 21-232); 90 FR 53227; Second FNPRM 90 FR 55826 (2025-12-04)
- EA-2026-01 DA 26-635 — prohibition on continued importation and marketing of previously authorized covered equipment added to the Covered List in 2024 or earlier (Huawei, ZTE, Hytera, Hikvision, Dahua, equipment integrating Kaspersky software): From 2026-07-16 importers may not import or market (sell, offer, ship, distribute) previously authorized Huawei/ZTE/Kaspersky-integrated equipment at all, nor Hytera/Hikvision/Dahua equipment for public-safety/government-facility/national-security purposes. Existing inventory cannot be sold in the U.S. (no sell-off period granted). — Released 2026-06-26; 91 FR 41023 (2026-07-06); effective 2026-07-16 · DA 26-635 (PS Docket 26-72); 91 FR 41023; comment PN DA 26-294 (2026-03-27; 91 FR published 2026-04-06)
- EA-2026-02 Third R&O FCC 26-50 — devices incorporating a "logic-bearing hardware component" produced by a Covered List entity cannot be authorized (47 CFR 2.903(b)(2)); Covered List entities barred from SDoC and permissive-change procedures for any modification (2.932(f), 2.1043): From 2026-10-13, any new device (any brand, any origin) containing a HiSilicon/Huawei, ZTE, Hikvision, Dahua or Hytera chip/module/sub-assembly cannot be certified or SDoC'd, hence cannot be imported for sale. Importers should obtain component-lineage attestations from suppliers (FCC says no new investigation duty beyond existing compliance, but applicant attestations are required and false attestations trigger streamlined revocation). — Adopted 2026-07-22; released 2026-07-23; 91 FR 57798 (2026-09-11); effective 2026-10-13 · FCC 26-50 (ET Docket 21-232); 91 FR 57798; fact sheet DOC-422746A1 (2026-07-01, FCC-CIRC2607-05); news release DOC-423291A1 (2026-07-22)
- EA-2026-03 Third R&O FCC 26-50 — online marketplaces (15 U.S.C. 45f(f)(4)) must display a valid FCC ID at the online point of sale for devices subject to certification; listing + fulfilment/warehousing/order-processing = "marketing" under 47 CFR 2.803(a)(1): Importers/e-commerce sellers must have a valid FCC ID for every certified device listed; marketplaces will delist products without one; marketplaces performing fulfilment are themselves "marketing" and liable under 2.803 for unauthorized/covered equipment without a willfulness requirement. — Rule effective 2026-10-13; compliance dates 2027-03-01 (para. (c)(1)) and 2027-06-01 (para. (c)(2)) · FCC 26-50; 91 FR 57798 (2026-09-11)
FCC proposed (not in effect) (2)
- P-2026-01 PROPOSED — Third FNPRM (FCC 26-50): cut 47 CFR 2.1204(a)(3) testing/evaluation import allowance from 4,000 to 40 units; bar devices with ANY component from a Covered List entity (or rebuttable presumption); mandatory HBOM/SBOM; 10-year term limits on authorizations; U.S.-based liable party for every certification; SDoC device registration with FCC-assigned ID; codify "produced in a foreign country" (FAR domestic end product), "UAS critical components" and "routers"; white-labeling disclosure; bifurcate Covered List; FCC logo restrictions; streamlined revocation; submarine-cable scope — Published 2026-08-07; comments 2026-09-08 / replies 2026-09-21; decision pending · FCC 26-50 Third FNPRM; 91 FR 51139 (2026-08-07)
- P-2026-02 PROPOSED — Second FNPRM FCC 26-28 (ET Docket 24-136): cease recognition of test labs, TCBs and accreditation bodies located in "non-Reciprocal Economies" (no MRA/reciprocal agreement with U.S.), withdraw existing recognitions with phase-out; $20,000 surcharge for equipment tested in such labs; extend to entities owned/controlled by or subject to jurisdiction of such economies — Published 2026-05-15; decision pending · FCC 26-28 (2026-04-30); 91 FR 27884; FCC 25-71 Second FNPRM 90 FR 55826