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Starting from October 13, 2026, the scope of the US FCC "Covered List" regulation will be further from "complete devices" to "logical carrier hardware components". For sellers, the range of affected products includes, but is not limited to, smart home devices, equipment, network communications, IoT hardware, robotics, and various consumer electronics with wireless functions (routers, cameras, walkie-talkies, mobile phones, tablets, sensors, etc.).

Note: For existing products that have already obtained an FCC ID before October 13, 2026, their import and sales will remain unchanged, and no retroactive enforcement or revocation will apply.

Interpretation of the New Policy

What is a "logic-bearing hardware component"? According to the FCC's explicit standards any physical component that meets either of the following criteria is considered as such:

Any component that generates or uses more than 9,000 timing pulse signals per second, or any component that relies on digital technology to perform RF operations, storage, and transmission, is included under regulation.

Typical forms include: System-on-Chip (SoC), Microcontroller Unit (MCU), Field-Programmable Gate Array (FPGA), Application-Specific Integrated Circuit (ASIC), RF modules, etc.;

There are also explicit exclusions: pure mechanical or passive components such as enclosures,, resistors, wiring, and ordinary battery cells are not counted.

The regulatory scope has expanded from finished products to internal components, aiming to more comprehensively prevent the influx restricted list hardware into the US market. The FCC included overseas consumer-grade routers in thelist in March this year and further expanded the scope in July, showing trend of expanding from product management to supply chain regulation.

However, the new regulations will increase the certification costs and cycles for sellers' subsequent new product development and hardware: changes in areas such as main control chips, replacement wireless modules, and firmware RF parameter modifications will no longer have a simplified change channel if they involve restricted list, requiring a complete re-submission for certification.

⚠️ Key Risk Warning: Once existing product listings are modified, they are no longer considered old 

products and must be-reviewed according to the new standards.

Two Control Paths

The new regulations are divided into two independent sets of restrictive rules, which many sellers easily confuse, leading to misged risks:

1.The restricted product categories for complete devices are: drones, routers, inverters, and robots. These four types of overseas-produced equipment included in the controlled list. Controlled objects: New models cannot obtain FCC certification, while old models are unaffected; this restriction is unrelated to internal chips.

Example If your router belongs to this category, even if the chip is not on the restricted list, the new product will not get certification; however, old models can be normally.

2. Chip manufacturer restrictions refer to: Chips produced by companies on the list. As long as the device contains these types of chips, the complete device will be directly rejected, regardless of the assembler or the brand.

Huawei, ZTE: All chip categories are restricted; Hikvision, Dahua, Hytera: targeting public safety, government security, and critical infrastructure monitoring scenarios; ordinary civilian cameras, if the manufacturer is not one of these three, are not restricted

Timeline for the new regulations

The new FCC ID regulations will take effect on October 13, 2026, and will be for physical products and third-party markets on March 1, 2027, and June 1, 2027, respectively. Sellers to pay attention to the timeline and complete the certification.

Seller Action Recommendations

It is recommended that sellers of products containing the following categories of electronic products conduct self-inspections:/Bluetooth smart hardware, security cameras, network routers, drones and robots, and other devices with wireless modules, as well as electronic products using complex main controllers and modules.

1. Distinguish the control routes: Drones, routers, inverters, and robots are controlled as complete machine categories, with a focus on reviewing selling permissions of older models;

2. Other powered products follow the chip control route, with a focus on tracing chip suppliers. Compile a product list to establish a for all powered products currently on sale or in transit, marking the category and supplier, and highlighting high-risk products in red.

3. Send written inquiries to, send compliance requirements to them, request a stamped written reply, and confirm whether the chip source is compliant.

4. Retain a full set of evidence: archive of FCC IDs for all products, properly store the suppliers' written replies as compliance backup materials. Freeze high-risk old listings and heavily affected categories, and suspend all modification operations.

5. It is recommended not to list your FCC ID under someone else's name. Using someone else's ID for free means that if holder files a complaint in the future, the listing and inventory will be gone together. Registering the ID under your own company name is your true asset

Conclusion

The impact of the new FCC regulations on Chinese electronic product export enterprises is mainly concentrated in the new product certification and core component stages. For manufacturers adopting multi-level supply chains, the manufacturer information of key components will become an important basis for assessing US market access risks.

Enterprises planning submit FCC certification applications in the near future should prioritize checking whether relevant components are subject to the covered list restrictions, and confirm whether existing applications and product changes comply with provisions. Enterprises selling related equipment through US e-commerce platforms also need to prepare FCC ID materials in advance to cope with the phased implementation of display and verification requirements in 2027.

Global United Technology Services Co.,Ltd. is an FCC-recognized laboratory in the US with NVLAP accreditation, capable of providing one-stop FCC ID compliance and certificates. If you have the need to export products to the US for FCC ID, you can contact Global United Technology Services Co.,Ltd. at any time to obtain professional answers and services.