The Rule Asks Who Made the Board
From October 13, 2026, a new FCC authorization can be refused because of one board inside the device. The rule asks who produced each logic-bearing part. A device built in Ohio around a listed producer's controller board is judged as if that producer had built the whole device, while a chip from a company that also makes routers abroad passes untouched unless that company is named on the Covered List in its own right.
Most of this regime runs on where equipment was made. Read a parts list that way, by country of origin, and it answers a question this rule never asks.
What takes effect on October 13, 2026
FCC 26-50, the Commission's Third Report and Order, was published at 91 FR 57798 on September 11, 2026 and takes effect October 13, 2026. It amends 47 CFR § 2.903(b) so that a device is prohibited from obtaining an equipment authorization if it incorporates "a logic-bearing hardware component produced by an entity identified on the Covered List." The prohibition holds where the device would have been barred had that entity produced the whole device rather than just the component.
The Commission's reasoning is that such devices "pose essentially the same unacceptable risks ... as if the device itself were produced by that Covered List entity." The bar applies "whether for certification or under the Supplier's Declaration of Conformity process," so self-declared equipment gets no separate path.
It looks forward only. Equipment already authorized "may continue to be marketed, imported, and used pursuant to its existing authorization." No petition for reconsideration had been filed as of October 5, 2026, and petitions are due October 13, 2026.
A producer test, never a location test
The Commission said where the bar stops. The prohibitions "apply only for logic-bearing hardware components produced by an entity identified on the Covered List." They do not reach components made by companies whose equipment falls under the production location entries, "such as components produced by entities that also produce UAS, UAS critical components, or routers in a foreign country," unless that company "is otherwise identified on the Covered List."
So the entries that carry most of this regime, the ones keyed to where a drone or router was made, put no component off-limits at all. The inverter and robotics entries are keyed to production location as well, and by the same reading they put no component off-limits either. The FCC's own FAQ on those two entries says a company that produces them in a foreign country is not considered identified on the Covered List.
The producers ¶ 37 points to
The order's own example of a company "otherwise identified" is one identified "in Section 1709 of the FY25 NDAA." That Covered List row, included December 22, 2025, carries the communications and video surveillance equipment and services listed in § 1709(a)(1) of the FY25 NDAA. The statute names equipment produced by Shenzhen Da-Jiang Innovations Sciences and Technologies Company Limited (DJI) and by Autel Robotics, and then reaches, for either of them, three further kinds of company.
- Any subsidiary, affiliate, or partner of the named entity.
- Any entity in a joint venture with the named entity.
- Any entity to which the named entity has a technology sharing or licensing agreement.
The roster, then, runs well past two brand names, and a supplier's name on an invoice says nothing about whether it stands in one of those relationships. The FCC's consolidated prohibited entities list will not settle it for you; its FCC Covered List filter returns neither DJI nor Autel, which sit on that page under the BIS Entity List (how that screen reads).
The rule's conditional decides what each producer's parts reach. The § 1709 row covers communications and video surveillance equipment when those producers make it, so the question for a device carrying one of their logic-bearing parts is whether the device is equipment of that kind.
The boards nobody calls chips
The new definition in § 2.902 is drawn from the "digital device" definition in § 15.3(k). It takes in any "device, system, module, sub-assembly, integrated circuit, or other physical component" that generates and uses timing signals above 9,000 pulses per second and uses digital techniques, and unlike § 15.3(k) it does not exclude intentional radiators. The Commission called wireless chipsets, "trust platform modules" and cryptographic elements "quintessential examples of logic-bearing hardware (though of course not exhaustive)."
Paragraph 28 sorts the parts a hardware maker buys every week.
- A plain battery cell is outside; a battery management system "likely contains control logic and would qualify."
- A bare motor with no embedded digital controller is outside; a motor controller or driver board "would likely qualify."
- Housings, chassis, brackets, fasteners and enclosures are outside.
- Resistors, capacitors, inductors, wiring and connectors that don't use digital timing signals are outside.
A drone, robot or inverter maker rarely thinks of a battery management system or a motor controller as a chip. It buys them as finished boards from a supplier, and the producer of that board is the producer the rule asks about. The Office of Engineering and Technology holds delegated authority to answer what meets the definition.
The Commission put that work on the maker. "An end user purchasing a connected device has no visibility into whether its logic bearing components originate from untrusted entities named on the Covered List," it wrote, and the device maker that "bears a one-time compliance cost to vet its supply chain is the more appropriate party to bear these costs." It pointed to NIST supply chain practices that include bills of materials identifying logic-bearing components, though no adopted rule text prescribes one. The full rule, question by question, is on the logic-bearing components page.
An amendment is a new application
An application filed with the Commission or a TCB before October 13, 2026 and still pending on that date is exempt from the bar. The Commission gave the reason; applicants in process "might not be able to substitute a replacement component without effectively restarting the authorization process."
The exemption is lost by amendment. It "does not apply to any pending application that is thereafter amended, after the effective date of this Order, to add, substitute, or change a logic-bearing hardware component; any such amendment shall be treated as a new application." A maker who discovers a listed producer's board in a pending filing after October 13, 2026 and swaps it out has started over under the rule, and so has one who changes a logic-bearing part for any other reason.
Where it lands
For a device maker filing on or after October 13, 2026, a logic-bearing part from a producer on that roster, in a device the rule reaches, means the device cannot obtain an authorization as built, by certification or by declaration.
For a buyer, the models already authorized keep shipping. The exposure sits in the model your vendor files for on or after October 13, 2026, or the one whose pending application it amends to change a logic-bearing part after that date. If it carries such a board, it does not reach the US market in the form you planned your next order around.