Frequently asked questions
The questions Gatewell answers in public, listed under the page that answers each one. They cover the FCC Covered List, federal contracts and grants, the defense supply chain, and the evidence that stands behind a claim of origin.
The FCC Covered List
How do I get equipment off the FCC Covered List?
Four routes take equipment off the FCC Covered List: domestic end product, a category exit, Conditional Approval, or a revised determination.
22 questions
- What is the FCC Covered List?
- Who decides what goes on it?
- My supplier was just added. What happens to what I already import and sell?
- Can a covered product still get an FCC equipment authorization?
- How does equipment come off the Covered List?
- What is Conditional Approval, and who grants it?
- How many Conditional Approvals have been granted so far?
- How long does a Conditional Approval take?
- What does “foreign-produced” mean?
- What does “produced by” mean, and does a redesign or re-sourcing change my status?
- My product is a router. Where do routers stand?
- Are robots and drones covered, and what about a bare platform?
- Can I change a covered product that was already authorized?
- Can I re-file the product under a different company?
- What changes on October 13, 2026?
- Does the component rule reach my router or drone?
- Does Section 889 apply to me if I sell to the federal government?
- I am an importer or distributor. What do I have to do now?
- What are the penalties?
- Do I need a consultant or a lawyer?
- How does Gatewell help, and what does it cost?
- Where is Gatewell, and whom does it serve?
What is the FCC’s logic-bearing hardware component rule?
From October 13, 2026 the FCC will not grant a new application for a device that carries a logic-bearing hardware component from a company on the Covered List.
13 questions
- What does the rule say?
- What is a logic-bearing hardware component?
- When does it take effect?
- Does it reach routers, drones, inverters and robots listed by where they are produced?
- Whose components trigger the bar?
- Are software and firmware covered?
- My application will be pending on October 13. Is it exempt?
- Can a sourcing change close the permissive-change path?
- Can a company named on the Covered List still use permissive changes?
- What changes for online marketplaces?
- When does an FCC ID have to appear on a listing?
- What should a manufacturer or importer do before October 13?
- Which services apply to the component rule, and what do they cost?
What a Conditional Approval is, and what it takes to get one.
What an FCC Conditional Approval is, who grants it, what the application must contain, what a grant carries, and what the published register shows.
14 questions
- Who grants a Conditional Approval, and how does the application get there?
- Can a distributor or an importer apply, or does it have to be the manufacturer?
- Can one application cover a whole product line instead of one model?
- What does the application have to contain?
- How many have been granted, and how fast did each category open?
- What does a termination date on a router grant actually mean?
- Why do UAS grants have no end date?
- Why does the robotics grant show no end date?
- What happens if the onshoring plan slips?
- Can I change the product while it is still covered?
- Does a Conditional Approval survive an acquisition?
- What gets an application refused?
- Does applying put my company on a list?
- Does a Conditional Approval protect a product I already sell?
What does an importer or distributor have to do about the FCC Covered List?
Import or market a covered model only under a valid FCC authorization not limited under 47 CFR 2.939(e). One limitation took effect July 16, 2026.
15 questions
- Didn’t Congress grandfather equipment authorized before the Covered List rules?
- Which equipment does the July 16, 2026 import and marketing ban cover?
- Why did the FCC refuse more time for inventory, goods in transit and spare parts?
- Which further FCC import bans have been proposed?
- How long would importers have to stop under the proposed bans?
- What do the proposed bans leave out?
- The FCC ID still shows as granted. Can the model still be imported?
- Can I screen suppliers against the affiliate lists the named companies filed with the FCC?
- How has the FCC acted against the drone companies named in DA 26-742?
- Do state procurement rules ban Hikvision, Dahua or other covered brands?
- What does Louisiana require of a vendor selling telecom or surveillance equipment to a public agency?
- Can a supplier’s goods be stopped at the port under UFLPA even if its FCC status is clean?
- How long do I have to respond to a UFLPA detention?
- What evidence does CBP need to release a detained shipment?
- What do vendor-bench diligence, site verification and the Detention-Ready Package cost?
How does a product qualify as a domestic end product under the FCC Covered List?
A robot or inverter is a domestic end product when made in the US with over 65% domestic component cost, 75% from 2029, under 48 CFR 25.101(a).
12 questions
- How much US content does a robot or inverter need to be a domestic end product?
- What counts as a component cost in the domestic content calculation?
- Does final assembly in the United States make a product a domestic end product?
- How can a power inverter fall outside the Covered List entry without a Conditional Approval?
- What does an inverter need to qualify through the 45X credit?
- Is there a domestic content test for routers on the Covered List?
- When does the domestic end product exception for drones end?
- What does the FCC’s FAQ say about the domestic end product test?
- Can switching a supplier cost my device its domestic end product status?
- Is the FCC domestic end product test the same as Build America, Buy America?
- Are the 45X percentages the same as the 65 percent domestic content floor?
- What does domestic content engineering cost?
What do I have to keep doing after an FCC Conditional Approval?
A Conditional Approval is not an FCC authorization. Each model still needs certification, and the approval's onshoring and reporting conditions continue.
14 questions
- Is my product FCC authorized once the Conditional Approval is granted?
- Can I sell or lease units after the Conditional Approval but before the FCC authorization?
- Does a device built with certified radio modules still need its own FCC testing?
- What happens to my authorization if the TCB that issued it loses FCC recognition?
- What do I have to report after a robotics or power inverter Conditional Approval?
- What keeps a drone Conditional Approval in effect?
- What does an FCC authorization application have to certify about the Covered List?
- Does a foreign manufacturer need a US agent for service of process to get an FCC authorization?
- What happens if our US agent for service of process stops responding?
- Can the FCC demand samples or records after my product is authorized?
- Can the FCC revoke an equipment authorization after it is granted?
- What has led the FCC to revoke equipment authorizations?
- Can the FCC stop imports of equipment it has already authorized?
- What does condition maintenance after a Conditional Approval cost?
Federal contracts and grants
Does Section 889 apply to my contract or my grant?
Section 889 reaches contractors through FAR 52.204-25 and its representations, and grant and loan recipients through 2 CFR 200.216.
20 questions
- What are the two Section 889 prohibitions?
- Does the Section 889 ban on using covered equipment reach equipment outside my federal work?
- Which companies and equipment does Section 889 cover?
- What counts as a substantial or essential component, or as critical technology?
- Which Section 889 representation do I sign, 52.204-26 or 52.204-24?
- What do I have to disclose if I answer “does” on the Section 889 representation?
- Do I have to check the System for Award Management before I sign a Section 889 representation?
- What does “reasonable inquiry” mean in a Section 889 representation?
- Does the reasonable-inquiry standard apply to a grant or loan recipient?
- I am a subcontractor. Which part of the Section 889 clause reaches me?
- Is there a dollar threshold or a commercial-item exception for Section 889?
- We have federal grant or loan money but no federal contract. What does 2 CFR 200.216 prohibit?
- How is the 2 CFR 200.216 grant rule different from the FAR clause?
- Does 2 CFR 200.216 bind a for-profit company with a federal award?
- Is a vendor paid with grant funds a subrecipient or a contractor?
- What do I report if covered equipment turns up during a federal contract?
- Can an agency waive Section 889?
- We receive E-Rate or high-cost support. Which covered-equipment rule applies?
- What would the proposed FAR overhaul change for Section 889?
- What does an integrator reasonable-inquiry file or federal-funds recipient screening cost?
The defense supply chain
What do the DFARS covered-materials rules require of a supplier?
Suppliers may not deliver covered magnets, tungsten or tantalum melted or produced in China, Russia, Iran or North Korea. The clause flows to any tier.
16 questions
- Which materials count as covered materials under DFARS 252.225-7052?
- Which statute and DFARS clause impose the covered-materials restriction?
- Which countries does the covered-materials rule cover?
- What changes for covered materials on January 1, 2027?
- Does DFARS 252.225-7052 flow down to subcontractors?
- Does a supplier sign a certificate under the covered-materials clause?
- Does Executive Order 14415 require an indentured bill of materials?
- What are the exceptions to the covered-materials restriction?
- What does the commercially available off-the-shelf (COTS) exception not cover under DFARS 252.225-7052?
- Does the electronic-device exception cover a samarium-cobalt magnet?
- Does recycled feedstock count under the covered-materials rule?
- Can a supplier still get a covered-materials waiver after January 1, 2027?
- Who makes a nonavailability determination for covered materials?
- How is the covered-materials rule different from the DFARS specialty metals rule?
- Which rules govern batteries and drones in defense supply chains?
- What does a covered-materials exposure diagnostic cost?
Origin evidence and the Protocol
The Gatewell Protocol for Origin Evidence.
An open documentation standard for origin evidence under the FCC Covered List. What the file contains, how it is verified, and how conformity is claimed.
What to require from a vendor of routers, drones, inverters or robots under the FCC Covered List
Clause language, a vendor questionnaire and the three conformity levels of the Gatewell Protocol for Origin Evidence, for buyers writing Covered List requirements into a solicitation or a supply agreement.
How a manufacturer proves a device is not foreign-produced under the FCC Covered List
What "foreign-produced" means by category, what a complete origin evidence file contains, how it is verified, and what the Conditional Approval path requires.
How an Origin Evidence File maps to the FCC’s proposed HBOM rule and to other supply-chain regimes
How an Origin Evidence File maps to the FCC's proposed HBOM and SBOM rule, to UFLPA, Section 889 and DFARS covered materials, and to IPC-1782, AS5553, SPDX and CycloneDX.
5 questions
What monitoring documentation for Build America, Buy America and Section 889 looks like
For auditors and finance officers: what the single audit asks a recipient to produce behind a vendor's origin certificate, what the federal rules actually specify, and the file that answers the question.
Talk to Gatewell
Gatewell Group is a compliance firm in Los Angeles. Start with the diagnostic, which takes two weeks, carries a fixed fee, and ends in a written judgment on your US pathway.