How does a product qualify as a domestic end product under the FCC Covered List?

The cost of domestic components must exceed 65 percent of total component cost for items delivered in calendar years 2024 through 2028, and 75 percent for items delivered from calendar year 2029. The robotics and inverter determinations of July 27, 2026 define a foreign-produced article as “any article that does not qualify as a ‘domestic end product,’ as that term is defined in 48 CFR § 25.101(a).” For robots the Buy American test is the coverage test itself. For inverters, since August 20, 2026, it is one of two exits.

The schedule was set by a Federal Acquisition Regulation (FAR) final rule, FAR Case 2021-008, published at 87 FR 12780 on March 7, 2022.

The FCC’s FAQ for these entries says the nationality of the entity producing a robot or inverter “is not relevant to whether such devices are ‘foreign produced.’” The full definition is on the Covered List FAQ. The floor itself is examined in The 65 Percent Question.

Source: 48 CFR 25.101(a) and 25.003; FAR Case 2021-008, 87 FR 12780, March 7, 2022; National Security Determinations on advanced robotic devices and power inverters, July 27, 2026; FCC DA 26-870, August 20, 2026; FCC Covered List FAQs on advanced robotic devices and power inverters, read September 8, 2026.

A component is “an article, material, or supply incorporated directly into an end product.” A purchased component counts at its acquisition cost, including transportation to the place of incorporation and any applicable duty. A component the applicant makes itself counts at all the costs of making it, including transportation and allocable overhead, excluding profit.

The cost of building the end product stays out of the calculation. Under 48 CFR 25.003, “cost of components does not include any costs associated with the manufacture of the end product.” Assembly, integration, design, labor and testing at the end-product level therefore sit outside both sides of the fraction. Labor and overhead count only inside the cost of a component the applicant makes itself.

The FAR treats a component of unknown origin as foreign. A software license is not, on the face of the definition, an article, material or supply. Firmware bought inside a chip is counted inside that chip’s acquisition cost. The FCC’s FAQ says commercially available off-the-shelf (COTS) components are “still counted” for robots and inverters. What that means for the evidence is answered in How a manufacturer proves a device is not foreign-produced.

Source: 48 CFR 25.003 and 25.101(a); FCC Covered List FAQs on advanced robotic devices and power inverters, read September 8, 2026.

Not by itself, because a product assembled in the United States still has to clear the component-cost floor. The cost of the assembly is a cost of manufacturing the end product, which 48 CFR 25.003 leaves out of the fraction.

The FAR defines neither “manufactured” nor “manufactured in the United States,” so whether final assembly alone meets the first part of the test is an open question.

For robots, the FCC’s FAQ says adding components that emit radio-frequency energy to a mechanical platform imported with no compute, sensors or RF renders the device covered equipment. The bare-platform question is answered on the Covered List FAQ.

Source: 48 CFR 25.003 and 25.101(a); FCC Covered List FAQs on advanced robotic devices and power inverters, read September 8, 2026.

Since August 20, 2026, the entry reaches only utility-interactive inverters as UL 1741 sections 2.1.23 and 2.1.52 define the term. An inverter that is not utility-interactive does not meet the definition. The Department of War’s stated reasoning is that units “incapable of connection to the utility grid” generally do not pose risk to the public utility grid.

A utility-interactive inverter is outside the entry if it is a domestic end product under 48 CFR 25.101(a) or if it is eligible for the § 45X credit for domestic production. The robotics definition was not changed on August 20, 2026, so a robot’s only content route is the domestic end product test.

The connectivity part of the definition reaches a unit that contains, or is “designed, equipped, or configured to accept,” a component enabling remote communication, control, sensing, data collection or monitoring, wired or wireless. An inverter shipped with an empty communications slot still meets it.

Source: FCC DA 26-870, August 20, 2026; Second Power Inverter National Security Determination, August 19, 2026; UL 1741 §§ 2.1.23, 2.1.52.

It has to be produced in the United States. § 45X(d)(2) takes sales into account only for eligible components “the production of which is within” the United States or a US possession. The § 45X route is therefore not available to an inverter made abroad.

The unit must be an inverter as § 45X defines it, “an end product which is suitable to convert direct current electricity from 1 or more solar modules or certified distributed wind energy systems into alternating current electricity.” It must also fall in one of the six capacity categories of § 45X(c)(2)(B) through (G), which are central, commercial, distributed wind, microinverter, residential and utility. § 45X(c)(1)(C) excludes from “eligible component” any property that includes any material assistance from a prohibited foreign entity.

§ 45X carries no domestic component cost floor. The percentage it does apply is a material assistance cost ratio under 26 U.S.C. § 7701(a)(52)(C). A US-produced inverter that misses the 65 percent floor can therefore still fall outside the entry on this route.

Source: 26 U.S.C. § 45X(c)(1)(C), (c)(2), (d)(2); 26 U.S.C. § 7701(a)(52); FCC DA 26-870, August 20, 2026.

The router entry names no content test. It covers routers produced in a foreign country, and its one exception is a Conditional Approval by the Department of War or the Department of Homeland Security.

The March 20, 2026 router determination, as cited in FCC 26-42, says “production generally includes any major stage of the process through which the device is made, including manufacturing, assembly, design, and development.”

Where routers stand is answered on the Covered List FAQ. The Conditional Approval route and the onshoring plan it carries are covered on Conditional Approval and in Reading the Onshoring Conditions.

Source: FCC Covered List, routers entry of March 23, 2026, read September 4, 2026; National Security Determination on the Threat Posed by Routers Produced in Foreign Countries, March 20, 2026, at 2, as cited in FCC 26-42, ¶ 76 and note.

The entry for uncrewed aircraft systems (UAS) excepts Buy American domestic end products under 48 CFR 25.101(a) until January 1, 2028. The July 21, 2026 superseding determination (FCC DA 26-761) extended that date from January 1, 2027. The entry’s Blue UAS Cleared List exception runs to the same date.

The robotics and inverter entries carry no such date, because their determinations write the test into the definition of “foreign-produced” itself.

Source: FCC Covered List, UAS entry, read September 4, 2026; DA 26-761, July 21, 2026; National Security Determinations on advanced robotic devices and power inverters, July 27, 2026.

The FAQ for robots and inverters says the commercially available off-the-shelf exception to the Buy America standard is “inapplicable” to whether a device is a domestic end product under 25.101(a). A COTS item manufactured in the United States therefore still has to clear the component-cost floor.

On evidence, the FAQ says applicants “will need to be able to have sufficient evidence that the device in question was not produced in a foreign country to make this certification, but there is no specific documentation or evidence required.” The FAQ for UAS says applicants “will need to demonstrate that UAS or UAS critical components were not produced in a foreign country to make this certification, but there is no specific documentation or evidence required.” What a sufficient file holds is answered on How a manufacturer proves a device is not foreign-produced.

Where the FAQ differs, the determinations, the Covered List entries and DA 26-870 govern.

Source: FCC Covered List FAQs on advanced robotic devices and power inverters, read September 8, 2026; FCC Covered List FAQs on UAS and UAS critical components, read September 29, 2026.

A change that would cost a device its domestic end product status cannot be made as a permissive change. The FCC 26-50 Third Report and Order clarifies that the bar on permissive changes in 47 CFR §§ 2.932 and 2.1043 applies to equipment “that would become prohibited as a result of the proposed modification.” Its examples include “a shift in production to a Covered List entity” and “a change that would cause a device to lose ‘domestic end product’ status.” From October 13, 2026, § 2.1043(a) provides that such changes “shall not be performed without application for and authorization of a new grant of certification.” Equipment that the change makes covered cannot obtain one.

The Commission “will not deem a device prohibited unless the modification itself renders equipment ‘covered’ equipment.” Switching to a supplier that pulls domestic component cost below the floor is a modification of that kind. The order was published September 11, 2026 at 91 FR 57798, and the Federal Register notice gives October 13, 2026 as its effective date.

Permissive changes in general are answered on the Covered List FAQ, and the content-floor case in The Class I Change That Needs a New Grant.

Source: FCC 26-50, Third Report and Order, ¶¶ 80 to 82, 91 FR 57798, September 11, 2026; 47 CFR §§ 2.932(a), 2.1043(a), effective October 13, 2026.

Build America, Buy America sets a lower floor. It treats a manufactured product as produced in the United States when it is manufactured here and the cost of its US components is greater than 55 percent of the cost of all components. The 55 percent figure is written into the statute, section 70912(6)(B) of the Infrastructure Investment and Jobs Act. The robotics and inverter determinations use the FAR test, at more than 65 percent for deliveries in 2024 through 2028 and 75 percent from 2029.

Both regimes compute component cost from the same text, 2 CFR 184.5 against 48 CFR 25.003. Part 184 is silent on components of unknown origin, which the FAR treats as foreign. Clearing the Build America, Buy America test does not clear the Covered List test. The evidence standard for Build America, Buy America is set out in its regime profile.

Source: Infrastructure Investment and Jobs Act, Pub. L. 117-58, § 70912(6)(B); 2 CFR 184.5; 48 CFR 25.003 and 25.101(a); National Security Determinations of July 27, 2026.

No. The percentages that reach § 45X components sit in 26 U.S.C. § 7701(a)(52)(C) and measure a material assistance cost ratio under the prohibited-foreign-entity rules. The inverter threshold there is 50 percent in 2026 and rises each year to 70 percent after 2029.

The 65 and 75 percent figures belong to 48 CFR 25.101(a) and measure the cost of domestic components against total component cost.

Source: 26 U.S.C. § 45X(c)(1)(C); 26 U.S.C. § 7701(a)(52)(C); 48 CFR 25.101(a).

Domestic content engineering is $20,000 to $85,000 per line. It maps the bill-of-materials pathway to the domestic-manufacture exit the determinations write into their own definitions, with substantial-transformation analysis. A binding-ruling addition from U.S. Customs and Border Protection is available.

A US onshoring plan is $65,000 to $125,000 and up. It covers site and electronics manufacturing services (EMS) partner selection, incentive mapping and capex phasing. The fee is priced by footprint.

Origin Evidence File assembly is $15,000 to $35,000 per line. It delivers the complete documentary file under Protocol v1.0.

The Covered-List Exposure Diagnostic is fixed at $7,500 to $15,000 and takes two weeks.

The full schedule is at Services.