FCC Covered List Component Rule: What Changes on 13 October 2026

What changed

Until now, the FCC’s Covered List prohibitions attached to finished equipment. A device produced by a listed entity could be refused authorization; a device produced by someone else that happened to contain that entity’s parts generally could not.

From 13 October 2026 that distinction closes. A device is prohibited from new FCC authorization if:

1. it incorporates a logic-bearing hardware component produced by an entity subject to a producer or provider based Covered List determination, and
2. the device would itself have been prohibited from authorization had that entity produced the whole unit.

A logic-bearing hardware component is defined by function, not by name: a device, system, module, sub-assembly or integrated circuit that generates and uses timing signals in excess of 9,000 pulses per second and uses digital techniques. In practice that is the SoC, the radio module, the MCU, the co-processor — the parts that decide what your product does.

Where your company is registered has no bearing on this. Who produced the logic parts on the board does.

The second test matters as much as the first

The rule is written as a counterfactual, and that limits it usefully. Covered List determinations are scoped to particular equipment and uses. A component from a listed entity only triggers the prohibition where the finished device is of a kind that entity would itself have been barred from getting authorized. Working out whether your device falls inside that scope is a product-by-product question, not a yes or no about a supplier name.

What the rule does not do

It does not revoke existing authorizations. The rule is prospective and applies to new applications. Equipment already authorized may continue to be marketed, imported and used under its existing grant.

It does not reach software or firmware. The Commission expressly declined to extend the prohibition to software or firmware components at this time. “At this time” is doing real work in that sentence — see What is coming next below.

It does not attach to production-location-only listings. A growing part of the Covered List is now based on where equipment is produced rather than who produced it: foreign-produced uncrewed aircraft systems, certain routers, and, since late July 2026, foreign-produced advanced robotic devices and power inverters. These do not by themselves trigger the component prohibition. They only do so where the producing entity is independently identified on the Covered List.

That distinction is easy to get backwards, and getting it backwards is expensive in both directions — either you disqualify a part you could have used, or you carry an exposure you think you have cleared.

Three details that decide real cases

The second beat: online marketplaces

The same Order extends the FCC’s marketing rules to online marketplaces. Listing regulated equipment now falls within “distribution for the purpose of selling”, including where the equipment is sold by a third-party seller. Enforcement under section 302(b) carries no willfulness or knowledge element, though the Commission has signalled it is unlikely to pursue marketplaces that carry out reasonable due diligence.

FCC ID display at the online point of sale follows on a staggered schedule:

• 1 March 2027 — marketplaces with physical access to, or title over, the device.
• 1 June 2027 — marketplaces relying on third-party seller certifications.

Listings published before the rule’s effective date and not later amended, listings by sellers that are not high-volume third-party sellers, and listings for used devices are treated differently under the display requirements.

For a European manufacturer this matters indirectly but concretely: your US distribution partners will start asking you for authorization data they never asked for before, and they will want it in a form they can publish.

Common questions