Expert PerspectivesManufacturing

The FCC Just Rewrote the AMR Shortlist

Quick Answer: Since July 28, 2026, foreign-produced mobile robots, including autonomous mobile robots (AMRs), can no longer receive new Federal Communications Commission (FCC) equipment authorizations without a Conditional Approval from the Department of War. The test is where a robot is manufactured and how much of its component cost is American, so European and Japanese AMRs are caught too. Models authorized before that date can still be bought and used. New models, AI upgrades, pilots and spares all face new limits, and the FCC hasn’t said whether fitting a 5G gateway to a grandfathered robot counts as modifying it. Integrators should track each model’s status and design private 5G AMR networks that can outlive any one robot vendor.

For an integrator running a private 5G AMR deployment at a Midwestern plant, the figure that now decides which robots it can buy is 65%, the share of a new mobile robot model’s component cost that US-made parts must exceed before the FCC will authorize it. The robot also has to be manufactured in the US, and a model that fails either test needs a Conditional Approval instead. The 40 robots already on the floor are an older model, authorized before the rule, and they run fine. The radios and the core passed acceptance testing in the spring.

Then the customer approves 60 more robots for next year, on the vendor’s new model. The new model missed the July 28, 2026 cutoff. It is built in Europe, so it fails the manufacturing test before anyone counts parts. Its only ways into the US now are a Conditional Approval or a move to US production, and nobody on the vendor call can say whether either will happen.

Every piece of the network is ready for 60 more robots. None of the robots is ready for the US market.

The Rule Reads Like a Spec Sheet for an AMR

On July 28, 2026, the FCC’s Public Safety and Homeland Security Bureau added “foreign-produced advanced robotic devices” to the Covered List in Public Notice DA 26-786, acting on a national security determination sent the previous day by a White House-convened interagency body. Equipment on the Covered List cannot receive an FCC equipment authorization, and without one most radio-emitting products cannot legally be imported, marketed or sold in the US.

Put the definition next to any AMR datasheet and every box gets ticked. A robot fits the definition only if it:

•       moves on the ground and operates at a distance from a human operator, based on commands or sensor data

•       weighs more than 4.4 pounds together with its dock

•       carries a sensor that perceives its environment

•       connects to a network, wired or wireless, at 200 kbps or more in either direction

•       runs software that controls its movement, navigation, perception, data collection or remote command-and-control

The FCC’s FAQ adds that automated guided vehicles (AGVs) may qualify even when they follow predefined paths.

The software clause counts AI and machine-learning model weights, whether they run on the robot or remotely. The physical AI that is pushing many of these fleets onto private 5G is part of the FCC’s definition of a robot.

Here is how the definition sorts common factory equipment:

EquipmentStatus if foreign-producedWhat decides it
Fixed robot arm, such as articulated, delta, gantry or selective compliance assembly (SCARA) typesExcludedThe determination carves out fixed, stationary robots.
Autonomous mobile robot (AMR)CoveredA typical AMR meets the mobility, weight, sensor, connectivity and software tests.
AGV on a predefined pathMay be coveredFollowing a fixed route doesn’t take it out of scope.
Arm mounted on a mobile baseLikely coveredThe arm moves with the base, so the stationary carve-out is hard to claim.

The maker’s nationality plays no part in the test. A robot counts as foreign-produced if it fails the Buy American “domestic end product” standard in federal procurement rules, so an AMR built in Denmark or Japan is as covered as one built in Shenzhen, and a US brand’s robot built in Asia is covered too.

Grandfathered Today Doesn’t Mean Grandfathered at Refresh

Because the listing looks forward, every AMR on a shortlist falls into one of three groups:

Model statusNew unitsSoftware updatesMain risk
Foreign-produced, authorized before July 28, 2026Can still be imported, marketed and soldAllowed through at least January 1, 2029, for updates that mitigate harmThe FCC could later restrict imports and sales, as it has for some older equipment and has proposed for some drones
Domestic end product (US-made, more than 65% domestic component cost)Outside the listing; normal FCC authorization appliesNormal FCC rules applyThe threshold rises to 75% in 2029, and the FCC hasn’t said how that applies to models already authorized
New foreign-produced modelBlocked without a Conditional ApprovalNot applicable until authorizedApprovals are scarce, and applications close January 1, 2028

For models in the first group, hardware changes are off the table, because covered equipment no longer qualifies for the FCC’s permissive change process.

Software is where the FCC left room. Its Office of Engineering and Technology lifted the ban on permissive changes for software and firmware updates that mitigate harm to US consumers, through at least January 1, 2029. The waiver notice says this includes updates that keep devices working, such as vulnerability patches and compatibility fixes.

The notice says nothing about capability upgrades. Physical AI fleets improve through software, with new navigation and perception models pushed to robots already on the floor, and the FCC has not said whether shipping one to a grandfathered robot counts as mitigating harm. Integrators should get the vendor’s position in writing before selling a roadmap that depends on it.

The longer-term risk is losing access to more of the same model, whether for replacements or for a growing fleet. FCC rules let the agency stop imports and sales of covered equipment it had already authorized. It did so on June 26, 2026 for older Covered List equipment. On July 17 and July 21 it proposed the same for drones from nine named companies and for military-grade drones, roughly seven months after listing foreign drones. The FCC has not started that process for robots, but a fleet that will need replacement units in 2028 should be planned as if it might.

PRO TIP: Keep a Model-Level Authorization RegisterFor every AMR model in your customer’s fleet and roadmap, record the FCC ID, whether it was authorized before July 28, 2026, where the finished robot is manufactured, and the vendor’s written position on domestic content and Conditional Approval. Add the vendor’s stated update policy. Review the register each quarter and whenever the FCC publishes a Covered List notice. The next time a customer asks whether they can still buy a model, the answer is already on one page.
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The 5G Gateway Question Nobody Has Answered

Plenty of AMRs reach a private 5G network through a box bolted onto the chassis. “We discovered that many of the robots or autonomous mobile robots (AMRs) don’t have the 5G module embedded,” Celona CTO Mehmet Yavuz told the E-Commerce Times in March 2026. Celona sells the fix as a service with Digi International, with Celona’s private 5G on the network side and Digi’s industrial routers and gateways on the robots.

A robot that already has a Wi-Fi radio meets the connectivity test with or without the gateway, so the gateway doesn’t decide coverage. The unanswered question is whether fitting a separately authorized cellular gateway to a grandfathered, foreign-built robot counts as changing that robot. If it does, the retrofit that puts the fleet on private 5G could run into the same restriction that blocks hardware changes. None of the FCC’s published guidance covers the point. For now, ask the robot vendor and regulatory counsel, and keep both answers on file.

The gateway itself is on firmer ground. The router listing from March 2026 covers consumer-grade devices meant for residential use, and the FCC’s FAQ says routers intended only for industrial, enterprise or military use are not covered.

One more date belongs on the calendar. From October 13, 2026, the FCC will stop authorizing new devices containing logic-bearing hardware components, such as cellular modules, from companies named on the Covered List, including Huawei and ZTE. A part from a manufacturer caught only by a category listing, such as robots or routers, doesn’t trigger it. Quectel and Fibocom, the companies that lead China’s cellular module industry, are not named, so the rule matters only if a gateway or robot carries a module or other logic-bearing component from Huawei, ZTE or another named company.

Pilots Shrink and the Bill of Materials Decides the Shortlist

Domestic status has a location test and a cost test, and a robot has to pass both:

•       It must be manufactured in the US.

•       Domestic parts must make up more than 65% of total component cost for items delivered through 2028, and more than 75% for deliveries from 2029.

•       Components of unknown origin are treated as foreign, so every part a vendor can’t trace works against it.

Allied parts don’t help. The robot rule uses the civilian Buy American test, not the defense version that credits components from qualifying partner countries. A US-built AMR that relies on imported drives, batteries and lidar can miss the line even if every import comes from an ally.

The FCC hasn’t said how the 2029 step to 75% will apply to US-made models already authorized under the 65% test. A vendor that clears 65% today by a thin margin should still have a plan for the higher number.

Pilots, which already struggle to scale, face a separate squeeze. Under a pending FCC proposal, published in the Federal Register on August 7, 2026, a vendor could import no more than 40 units of an unauthorized covered model for testing, evaluation or product development, unless the FCC’s engineering office approves more in writing. The current limit for unauthorized devices is 4,000. Pilots on models authorized before July 28 wouldn’t be affected.

PRO TIP: Ask Your AMR Vendor These Five QuestionsBefore you commit to a fleet expansion, put these to the vendor:1.    Was this exact model authorized before July 28, 2026?2.    Where is the finished robot manufactured, and if it’s in the US, what is its domestic component-cost share and who calculated it?3.    Have you applied for Conditional Approval, and for which models?4.    Which planned software and AI updates do you believe fall inside the FCC’s update waiver?5.    Does fitting our 5G gateway affect the robot’s authorization?Ask for every answer in writing.

Design the Network to Outlive the Robot Shortlist

Three dates should go into every AMR program plan:

•       October 13, 2026: the ban on logic-bearing components from companies named on the Covered List takes effect for new FCC authorizations.

•       January 1, 2028: applications for Conditional Approval close.

•       January 1, 2029: the domestic-content threshold rises to 75%, and the software update waiver could end as early as this date.

For a foreign-produced model that wasn’t authorized before July 28, Conditional Approval is the only way into the US market short of qualifying as a domestic end product. Only the Department of War can grant it, and its decisions are final.

So far, the only robotics approval has gone to Husqvarna, on September 9, 2026, for four robotic lawn mower platforms. No industrial AMR vendor has announced one.

A site’s private 5G network is meant to run for years, and the robots on it may come from a different vendor in three. In practice, that means:

•       Device qualification doesn’t assume one vendor’s modem.

•       The reference design keeps an external gateway option.

•       The fleet management software can dispatch robots from more than one maker.

•       Capacity is planned for a transition period when two fleets share the floor.

Where Does This Leave You?

If you are a systems integrator or solution provider, the rule expands your role again: your customers will now expect you to know whether a private 5G AMR deployment can grow. Few of them will track Covered List notices, and a robot vendor is rarely a neutral judge of its own products’ status. Treat regulatory status as part of device qualification, next to radio frequency (RF) performance and handover behavior, and offer vendor diligence as a paid part of scoping. The answers on gateways and AI updates may take months, and your customers will need someone who can tell them what is settled and what is not. Vendors with a credible domestic content story, or a clear Conditional Approval plan, have something buyers now want to hear. The Executive Voice Program and Partner With Us are built for making that case to the integrators and enterprise teams who read this platform.

If you run IT or operational technology (OT) for a plant or distribution center, confirm the authorization status of the exact AMR model in writing before you approve any fleet expansion, and ask how the vendor plans to handle software updates after January 2029. Budget for the possibility that your next generation of robots comes from a different supplier, and make sure the private 5G AMR network you are building doesn’t lock you into the current one. A private wireless readiness self-audit is a practical first step in checking whether your network could handle that change.

FAQ

Our AMRs are built in Denmark. Does the rule still apply to us?

Yes. A robot built in Denmark fails the US manufacturing test, so it counts as foreign-produced however many American parts it contains. Models authorized before July 28, 2026 remain available. Any new model needs either US production that passes the domestic-content test or a Conditional Approval from the Department of War, and the approval process asks applicants for a plan to expand US manufacturing.

Can we keep adding robots of the model we already run?

Today, yes. Anything authorized before the cutoff can still be imported, marketed and sold. The risk sits further out. The FCC has already stopped imports and sales of some previously authorized equipment in other categories, and it has proposed doing the same for some drones. A fleet plan that depends on buying the same model for years should include a fallback. Watch for hardware revisions too. A covered model can’t take a hardware change, so a parts shortage that forces the vendor to redesign could end supply of that model sooner than any FCC action.

Does private 5G make a robot more or less likely to be covered than Wi-Fi?

It makes no difference. Any wired or wireless connection of at least 200 kbps in either direction meets the connectivity test, whether Ethernet, Wi-Fi, cellular, Bluetooth or satellite. Either way, a private 5G AMR network should be designed so a change of robot vendor doesn’t force a redesign.

Will the FCC shut down robots we already own?

No. The listing does not affect continued use of robots already purchased, and authorized models can receive qualifying software and firmware updates through at least January 1, 2029. What happens after that date has not been decided. A repair that swaps in different hardware may count as a change to the robot, so check with the vendor before approving one.

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