The FCC Covered List: National Security, Economic Policy, and Technology Supply Chains

The Federal Communications Commission’s (FCC) Covered List is a statutory mechanism for the federal government to identify communications equipment and services that pose an unacceptable risk to U.S. national security or the security of U.S. persons. Since its first publication in March 2021, the Covered List had focused on specific equipment and services of certain named suppliers from countries of concern, such as China and Russia. Since late 2025, however, the FCC has implemented national security determinations issued by a White House–convened executive branch interagency body to cover entire categories of foreign-produced technology, including drones, advanced robotics, consumer routers, and certain power inverters, subject to certain exceptions. Because these Covered List updates are not currently subject to standard notice-and-comment rulemaking, they are implemented through determinations and Covered List actions, limiting advance transparency regarding their scope and implementation.

The expansion raises questions about how the administration can use the Covered List to effectively reduce national security risks without undermining other goals, including strengthening domestic manufacturing, maintaining resilient supply chains, improving cybersecurity, preserving access to trusted foreign technology, and collaborating with allies and partners.

Q1: What is the Covered List?

A1: As defined by the FCC, the Covered List is a list of communications equipment and services that are considered to pose an unacceptable risk to the United States. The Secure and Trusted Communications Networks Act of 2019 gave the FCC the authority to create and maintain the Covered List. While the FCC has statutory responsibility for the list, it relies on national security determinations about which equipment and services should be included by expert bodies within the executive branch, such as the Department of Defense and the intelligence agencies. Recently, these determinations have been issued through a White House–convened interagency process.

Subsequently, under the Secure Equipment Act of 2021, Congress mandated that the FCC prohibit grants of equipment authorization for equipment falling under the Covered List. That legislation connected the Covered List to the FCC’s existing equipment authorization program, which has historically focused on technical issues such as radiofrequency compliance, and extended it to include national security reviews of newly covered equipment. Where equipment authorization is required, companies with a newly covered model generally cannot receive authorization and thus cannot be newly imported, marketed, or sold in the United States unless subject to an exception. Previously authorized models are not automatically taken off the market, subject to any subsequent FCC action.

Q2: How has the Covered List changed in recent months?

A2: The Covered List has recently been expanded to include a broader list of technologies. In December 2025, a White House–convened executive branch interagency process decided to add uncrewed aircraft systems as well as critical components produced by foreign countries, including U.S. allies and partners, to the list.

Additionally, in March 2026, that interagency process directed the FCC to add consumer-grade routers produced in foreign countries to the list, subject to specific approvals. Finally, in July 2026, the FCC added two new categories manufactured in foreign countries to the list: advanced robotic devices and power inverters.

The government’s rationale for these changes relies on a combination of cybersecurity and supply chain concerns. Regarding cybersecurity, public U.S. government reporting on the Chinese state-sponsored Volt Typhoon and Salt Typhoon campaigns heightened concerns that compromised internet-connected devices and network infrastructure could be used by foreign adversaries to gain unauthorized remote access to sensitive data, conduct espionage, or facilitate disruption. U.S. officials have warned that compromised routers may serve as entry points into networks or be used to conceal malicious activity. These incidents highlighted the risks of compromised equipment, though they did not by themselves demonstrate that foreign production—particularly in the case of close allies and partners—necessarily compromises U.S. networks. For supply chains, the concern is that dependence on overseas production can create risks to supply availability.

These security and supply chain issues also raise questions about how broadly restrictions should apply, particularly when designations extend beyond specific high-risk suppliers to cover broad product categories produced in allied and partner countries. A central question is whether domestic production substantially reduces risks compared to secure production by trusted allied suppliers, and how to strengthen domestic capacity while preserving the allied supplier and production-location diversity that can contribute to resilience. Allied and partner governments have also sought clarity on the continuing role of trusted suppliers based in their countries.

Q3: How are these changes affecting U.S. businesses that depend on foreign-made equipment?

A3: The effects are still unfolding, and they vary based on the specific product, its authorization, and its supply chain. Businesses can generally continue to buy previously authorized models, but they may face restrictions on new models or modified designs that require a new authorization. The newer location-based entries can affect a U.S.-headquartered company that designs or sells a product in the United States but relies on final assembly abroad, even if it doesn’t have any adversary-linked suppliers. This marks a significant change from the earlier entity-based approach, which principally targeted named providers. Moving final assembly to the United States may also not resolve a distinct problem: sourcing components that aren’t available outside foreign supply chains.

The Commercial Drone Alliance, an industry association that represents both domestic and allied unmanned aerial systems manufacturers and operators, has warned that “[a] broad prohibition that effectively cuts off critical components from even our closest allies risks disrupting critical operations, stalling innovation.” In the case of routers, the FCC granted targeted waivers allowing manufacturers to substitute certain components after they ran into shortages in memory and other components that were used in previously authorized devices. That case demonstrates the practical challenges in implementing these changes, as well as the potential to provide targeted flexibility.

In assessing these rules, it is important to distinguish between component restrictions and finished-product restrictions. The rule the FCC adopted in July concerns certain logic-bearing hardware components made by entities already on the Covered List; it does not extend production-location restrictions to all foreign-made parts. Logic-bearing components are physical parts that provide data processing or computing functions, including certain microprocessors, microcontrollers, modules, and communications chipsets. Thus, the rule raises traceability and supply-chain compliance questions, though it doesn’t create a blanket prohibition on all foreign-made components.

Q4: What could the Covered List mean for the U.S. market?

A4: The growing Covered List could have several implications for the U.S. market. Broad restrictions could require U.S. companies to identify alternative suppliers, redesign products to be created without restricted parts, or relocate production. This could have implications for U.S.-headquartered brands that manufacture abroad, because the newer entries restrict products by where they are produced. Industry groups warn that new models may face approval bottlenecks, which could lead to fewer product choices and higher prices. Compliance with FCC restrictions could increasingly become a competitive advantage for vendors. Better-resourced companies may be better positioned to absorb certification costs and diversify suppliers, while smaller manufacturers and importers could face barriers to market entry or exit the market entirely. As a result, while the Covered List may reduce exposure to untrusted technologies, it could also limit competition and increase dependence on a smaller group of suppliers.

For producers of some covered products, one route to market is a conditional approval. Conditional approvals are not blanket waivers that apply cross product categories, but rather they only apply where a Covered List entry provides that pathway and are subject to the specified conditions and processes. A distinct FCC waiver process—which is even more narrow—has been used for limited changes to previously authorized equipment, such as security-related updates. The details of both pathways—including criteria, conditions, duration, and renewal—will determine whether companies have sufficient certainty to make investment decisions. In some cases, the FCC’s actions present an opportunity for domestic manufacturers. The extent to which that expansion occurs with speed and scale will help determine the broader effects on U.S. businesses and consumers. When foreign products are excluded, the availability of domestic alternatives—and how they compare on cost, performance, and other requirements, which may vary substantially depending on the product category—will determine the effects on U.S. businesses and consumers.

It will be important for policymakers to weigh any resulting tradeoffs against the concrete security benefits of the Covered List designation. Depending on the product or component, these tradeoffs may be minimal, diminish as domestic production scales, or persist over the longer term. A September 2026 study estimates that the actions already adopted could cost regulated entities approximately $5.3 billion over five years, while the FCC’s $489 million estimate covered the July equipment-authorization rule package. For the U.S. market, these modeled costs could fall on consumers through reduced options and higher costs, and on smaller firms with limited capacity for absorption. While these two estimates encompass different sets of actions and should not be treated as comparable to one another, they nevertheless raise the question of whether the national security benefits of Covered List expansion outweigh the economic costs.

Q5: What can we expect on the Covered List going forward?

A5: The effectiveness of a Covered List designation should be evaluated by how effectively it reduces national security risks while minimizing unintended consequences for U.S. companies and consumers. This can be assessed by evaluating whether restrictions prevent the deployment of vulnerable or untrusted technologies, whether alternatives are available, and whether the security benefits outweigh supply chain disruptions.

Given the FCC’s use of categorical restrictions, this approach may serve as a template for future designations. These designations may include optical transceivers, which are critical components of data centers and telecom networks that enable data to be transmitted over fiber; connected cameras; or Internet of Things modules. While these categorical restrictions may be efficient in addressing potential risks across broad categories of technology, they may also include products with differing levels of risk.

The FCC’s pending Third Further Notice of Proposed Rulemaking, published in August 2026, signals where further expansion of this approach may be headed. Responding to the Covered List’s recent expansion to location-based entries, the FCC proposed splitting the list into producer-based and location-based categories, requiring certification for all devices in a “Covered List sector,” and extending restrictions deeper into the supply chain through hardware and software bills of materials and bans against devices containing Covered List components. It would also make permanent the waivers allowing security patches to currently authorized equipment.

Another critical issue will be how conditional approvals and FCC waivers are addressed. Building on the product-specific conditional approvals and narrow FCC waivers already available in particular circumstances, a transparent and predictable process could help companies meet administrative requirements while enabling them to continue delivering products and services to consumers and other businesses. This process should not be confused with Department of Defense procurement waivers, which address DOD purchasing rules and do not change FCC equipment-authorization eligibility.

Consistent communication and coordination with allied and partner governments as the FCC undertakes Covered List actions could further support trusted supply chains.

Congress may also play a role in the future of the Covered List. In September 2026, Ranking Member Frank Pallone Jr. (D-NJ) and Chairman Brett Guthrie (R-KY) of the House Committee on Energy and Commerce introduced a bipartisan bill titled the Communications and Technology Transparency Act. Broadly, the proposed legislation would specify which items can be added to the Covered List and clarify the process by which the FCC can add these items. On scope, it would expand the covered items to “information and communications technology or service[s],” while limiting the FCC to products or services controlled by foreign adversaries, including China, Russia, Iran, and North Korea. In terms of process, the bill would remove the interagency determination mechanism used in recent decisions on broad technology categories but retain a mechanism involving Commerce Department information and communications technology transaction prohibitions that the National Telecommunications and Information Administration notices to the FCC. The bill would also bar covered entities and their affiliates from having FCC licenses and other grants of authority, though equipment authorizations would not be part of that broader prohibition. Finally, it would specify that the FCC does not need to review or revoke equipment authorizations granted before relevant equipment was included on the Covered List.

The current version of the bill is prospective; thus, unless the bill is amended, it would not itself remove or modify existing Covered List entries. Whether or not the bill will advance remains unclear. In the meantime, the FCC’s existing authority to update the Covered List remains in place.

Matt Pearl is director of the Strategic Technologies Program at the Center for Strategic and International Studies (CSIS) in Washington, D.C. Kuhu Badgi is program coordinator and research assistant in the Strategic Technologies Program at CSIS.