The chip inside the module: what the FCC's first component refusals mean for your BOM

In September we wrote about the FCC Covered List component rule. It has now been used. On 22 October the FCC announced that its Office of Engineering and Technology (OET) had stopped two devices, a dashboard camera and a wireless video transmitter, from being marketed or sold in the United States. Both contained a chip produced by HiSilicon, which the FCC describes as a Huawei subsidiary and a Covered List entity. The FCC calls it the first enforcement of the component rules.

The FCC did not name the makers or models, or say how the chip got there, and we won’t guess. What the case shows is where the question now gets asked: at equipment authorization, before a product can be sold.

What the rule bars

Since 13 October, the FCC will not authorize a device that incorporates a “logic-bearing hardware component” produced by a Covered List entity, where the device would have been barred had that entity made the whole thing (Federal Register, 11 September 2026). The definition in the Third Report and Order covers any device, system, module, subassembly, integrated circuit or other physical component that meets a test drawn from the FCC’s definition of a digital device in 47 CFR 15.3(k) (¶28). Software and firmware are not covered “at this time” (¶30).

Three details matter for planning:

• Who produced it. “Produced by” is judged on the totality of the circumstances: who had substantial responsibility for or control over design, development, manufacture or assembly (¶83).
• Pending applications. An application already pending on 13 October is exempt. If it is amended after that date to add, substitute or change a logic-bearing component, it is treated as a new application (¶39).
• Existing grants. The prohibition is prospective. Equipment authorized before 13 October may still be marketed, imported and used (¶38).

Most BOMs stop at the module

In most of the bills of materials (BOMs) we review, the line item is the module: a camera module, a video transmitter, a cellular or Wi-Fi module, with its supplier part number. The chip inside it is not listed, so nobody reviews it.

The rule removes the shortcut. An integrated circuit is a logic-bearing component in its own right, so a module from a supplier that is not on the Covered List can still carry a part from one that is. For a product heading to the US, the question is no longer only “is this module certified?” but “what is inside it, and who made each logic-bearing part?”

The practical answer is to push the BOM one level down for anything that processes data or handles RF: camera modules, video links, radio modules and any subassembly with its own processor. Ask suppliers for the main integrated circuits and their producers, in writing, and keep the answer in the design file.

Where it surfaces: the filing

For many teams, the FCC application is the first hard look at what is inside each module. That is the worst time to find a problem part: the board is laid out and the test reports are paid for.

The knock-on effects reach past the FCC. PTCRB’s programme document (11.3.1.8) requires a manufacturer selling into the US to obtain an FCC grant and enter the FCC ID before PTCRB certification is granted, so a cellular product that stalls at the FCC also stalls at PTCRB. And if the fix lands after the application is filed, it is a component change under ¶39, which means starting that application again.

Back to the board

Replacing a logic-bearing part is rarely a drop-in change. A different processor or video transmitter brings different power rails and current peaks. A new radio module means new RF matching and antenna tuning, and the antenna has to be verified again in the product, not just on the module’s reference design. New clocks and new fast interfaces change the emissions picture, which means testing radiated emissions and immunity again, including ESD. That is a board spin.

For a European maker, there is a second decision. If the US variant needs a different module, either the European product keeps the old part and you now run two BOMs, or both change and the CE technical documentation under the Radio Equipment Directive (RED) needs updating too. A change for the US only can reach back into the main product. That choice belongs in design review, not after an application is turned away.

AI design tools: promising, not there yet (our view)

AI tools for PCB layout and parts selection are well funded. Flux has raised $37M, Quilter a $25M Series B and CELUS a €25M Series A. In our view, tools like these could take real pressure off teams trying to keep a BOM current while the rules keep moving.

They don’t close this gap yet. No tool we found claims to screen the chips inside a certified module against the Covered List. Z2Data says it screens for Covered List companies down through sub-tier suppliers, which maps the supplier chain rather than the parts inside a module. One risk is new. If a tool suggests an “in stock alternative”, it can bring in a covered part, and after a grant that is a component change, not a quiet swap.

What it doesn’t cover

The component rule is about who produced a part, not where it was made. Under ¶37, components from companies that are on the list only because of where they produce (foreign-produced drones and drone critical components, and routers) are not caught unless the company is otherwise identified on the Covered List. Those categories have their own route: Conditional Approvals from the Department of War (DoW) or the Department of Homeland Security (DHS), tied to an onshoring plan. The FCC published more of them on 2 October (DA 26-1063) and 23 October (DA 26-1154).

Two Covered List bills, S.1962 and H.R. 10453, are still pending. On 29 October the Commission adopted rules on where equipment testing and certification can take place (FCC 26-73).

What happens next (our view)

• More refusals in camera and video categories first. Both first cases were video devices, and the FCC says it will continue to aggressively enforce the rules.
• Questions move earlier. Expect labs and US customers to ask who produced the key chips before a filing.
• Module suppliers respond. Expect producer declarations for the main integrated circuits. A quiet chip change inside a module you already use is a change control risk: same part number on your BOM, different logic-bearing component inside.

What to do this quarter

If you have a US filing planned in the next year, take the BOM one level down now and get the chip producers in writing. If anything comes back from a Covered List entity, decide whether it is a change for the US only or a platform change. A design review and, if needed, a board spin before the filing cost far less than a component change after it.

Nothing here is regulatory advice. Facts checked as at 1 November 2026.