Questions on Conditional Approval
Who grants a Conditional Approval, and how does the application get there?
The Department of War grants it. For power inverters, routers and UAS the Department of Homeland Security can review instead. The Commission does not make the national-security call. An application arrives at the FCC by email, to conditional-approvals@fcc.gov as a machine-readable PDF, or to drones@fcc.gov for uncrewed aircraft.
Source: Conditional Approval guidance to the National Security Determinations of July 27, 2026, intake section.
Can a distributor or an importer apply, or does it have to be the manufacturer?
Any entity involved in producing the device can apply. The Commission was asked directly whether the applicant must be the manufacturer, the OEM that designs the device, or a service provider that purchases them, and that was its answer. It did not extend the answer to a party with no role in production.
Source: FCC Covered List FAQs on advanced robotic devices and power inverters, Conditional Approval section, read September 8, 2026.
Can one application cover a whole product line instead of one model?
Yes. The National Security Determinations permit applications covering classes of foreign-produced advanced robotic devices and power inverters. The register shows the practice running in the router lane, where Calix moved from a single model on May 6, 2026 to a four-model list on June 1 to a class grant on July 24.
Source: FCC Covered List FAQs, Conditional Approval section, read September 8, 2026; FCC Covered List, Conditional Approvals tab, pulled September 10, 2026.
What does the application have to contain?
Ownership, supply chain and a time-bound US manufacturing plan. Ownership runs to beneficial owners at five percent equity or more and any foreign-government ownership, control, influence, financing or material support. Supply chain is a full bill of materials with country of origin for every component.
The plan justifies why the device is not currently manufactured in the United States and commits capital over one to five years. The guidance does not set a standard of proof.
Source: Guidance Documents for Power Inverters and Advanced Robotics Conditional Approvals, Annex A to the National Security Determinations of July 27, 2026.
How many have been granted, and how fast did each category open?
18 for UAS, 21 for routers, one for advanced robotic devices, and none for power inverters, as of the register pull of September 10, 2026. UAS opened March 17, 2026, routers April 14, three weeks after listing, and robotics September 9, six weeks after listing. Power inverters were listed the same day as robotics. They are still at zero. Our reading of every grant on the register is public on this site.
Source: FCC Covered List, Conditional Approvals tab, pulled September 10, 2026.
What does a termination date on a router grant actually mean?
It is the date the approval stops. Every router Conditional Approval on the register as pulled September 10, 2026 carries one. The earliest falls October 1, 2027, and the most recent pair, ASUS Computer International and Comtrend Corporation, run to March 6, 2028. The dates cluster rather than counting a fixed term forward from each grant.
Source: FCC Covered List, Conditional Approvals tab, pulled September 10, 2026; FCC Public Notice DA 26-957, September 9, 2026.
Why do UAS grants have no end date?
They run indefinitely, on a condition. Since the National Security Determination of July 21, 2026, a UAS approval that shows no termination date remains effective, in the register’s words, “so long as the entity that received Conditional Approval abides by the onshoring plan outlined in its Conditional Approval application and pursuant to updated vetting of the products.” The onshoring plan is the renewal mechanism.
Source: FCC Covered List, Conditional Approvals tab and appendix footnote, pulled September 10, 2026.
Why does the robotics grant show no end date?
The record does not say. The register shows the Husqvarna AB grant of September 9, 2026 with a start date and nothing after it. The appendix footnote that makes an open-ended grant indefinite is written for UAS and keyed to the determination of July 21, 2026, so it cannot account for this grant.
Source: FCC Public Notice DA 26-957, Appendix B and appendix footnote, September 9, 2026; FCC Covered List, Conditional Approvals tab, pulled September 10, 2026.
What happens if the onshoring plan slips?
You report it. A dedicated point of contact files status with the issuing agency quarterly, and material changes must be disclosed promptly. No action against a Conditional Approval holder over onshoring performance has been published. A knowing violation or material misrepresentation terminates the approval and precludes re-applying.
Source: Conditional Approval guidance to the National Security Determinations of July 27, 2026, onshoring section; FCC Covered List, appendix footnote, pulled September 10, 2026.
Can I change the product while it is still covered?
Software and firmware updates are permitted under a waiver. Hardware changes are not. Covered equipment is excluded from the permissive-change procedures at 47 CFR 2.932(b) and 2.1043(b).
The Office of Engineering and Technology waived that bar for software and firmware updates to covered power inverters and advanced robotic devices authorized before July 28, 2026, at least until January 1, 2029. From October 13, 2026 the bar also reaches a change that would move production to a Covered List entity.
Source: 47 CFR §§ 2.932(b), 2.1043(b); OET Public Notice DA 26-789, ET Docket 21-232, July 28, 2026; FCC 26-50 Third Report and Order, 91 FR 57798, effective October 13, 2026.
Does a Conditional Approval survive an acquisition?
The public record does not answer that for the approval itself. Equipment authorizations do not expire and there is no renewal procedure. What a change of control does trigger is a fresh certification that the equipment is not prohibited under 47 CFR 2.903. Treat it as a material change to disclose to the issuing agency.
Source: 47 CFR §§ 2.903, 2.927(a), verified August 23, 2026; Conditional Approval guidance to the National Security Determinations of July 27, 2026, material-change disclosure.
What gets an application refused?
The record does not show, because denials are not published. Only grants reach the register. All decisions are final. A knowing violation or material misrepresentation terminates the approval and precludes the applicant from re-applying.
In August 2026 the Commission revoked both equipment authorizations held by Odyssey Robot LLC after the company said its drones were assembled in Texas and the named Texas assembler told the Commission it had never had any connection with them. Agencies write to the counterparties named in a file.
Source: Conditional Approval guidance to the National Security Determinations of July 27, 2026, certification section; FCC Order of Revocation DA 26-839, ET Docket 26-186, August 11, 2026.
Does applying put my company on a list?
No. The four category entries reach equipment by where it is produced. The Commission’s August 20, 2026 notice on the inverter entry states that these entries are identified “by place of production, not by entity.” An entity producing those devices in a foreign country is not considered identified on the Covered List.
Source: FCC Public Notice DA 26-870, August 20, 2026; FCC Covered List FAQs, read September 8, 2026.
Does a Conditional Approval protect a product I already sell?
On the drone precedent, yes, for as long as it remains in force. The Commission has begun prohibiting the importation and marketing of previously-authorized covered equipment. Two July 2026 notices propose extending it. Both expressly place equipment granted a Conditional Approval outside the prohibition.
Source: FCC Public Notices DA 26-742, July 17, 2026, and DA 26-758, July 21, 2026; 47 CFR § 2.939(e).
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