Gatewell Group
An open standard · Version 1.0 · Public comment draft · Revision 2

The Gatewell Protocol for Origin Evidence.

The FCC’s guidance says an applicant must hold “sufficient evidence” that a device was not produced in a foreign country, and that “there is no specific documentation or evidence required.” The Gatewell Protocol for Origin Evidence is an open, versioned documentation standard for that evidence. It specifies what an origin-evidence file contains, how the file is verified, and how conformity is claimed. It is free to use, cite and require of vendors.

Version 1.0, Revision 2, dated September 17, 2026, is open for public comment through October 31, 2026. The text of the standard is published under CC BY 4.0. The buyer’s-kit clauses, the vendor questionnaire and the file schemas are released under CC0.

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Level 1 conformity mark Documented Level 2 conformity mark Verified Level 3 conformity mark Monitored

The marks for the three conformity levels. Each level is defined in Part III.

Version 1.0, Revision 2 · September 17, 2026
Conformity

How a file reaches each level.

An Origin Evidence File is assembled once and maintained against the record it describes. The three conformity levels differ in who stands behind the file and in how long a claim stays current.

Verification under Version 1.0 opens with the final text.

Step one

Determine coverage

For each model, a determination of whether it falls within each potentially applicable Covered List entry, made against the operative definitions the listings incorporate rather than paraphrases of them. The record quotes the definition text with its source and retrieval date, works through the criteria against document IDs, and states the conclusion. A determination that a model is not covered identifies the specific definitional element that is not met. Clause 4.2.

Step two

Assemble the Origin Evidence File

Part IV sets eight sections. Device identity reconciled to public FCC records (4.1); the coverage determination (4.2); every production, assembly, firmware-loading and testing site, attested by an officer of its operator (4.3); a bill of materials with country of origin per line, deep-trace declarations one tier up, a concentration summary and a sole-source register (4.4); the ownership chain, five-percent beneficial owners, board and executive nationality, and any foreign-government influence, expressly stated (4.5); an SBOM with software, firmware and build-infrastructure origin (4.6); document IDs, certified translations, evidence-age limits and ten-year retention (4.7); and the officer attestation that closes the file (4.8).

Level 1

Documented

A complete file under Part IV, every element officer-attested on the Annex A certification, declared by the manufacturer itself. The officer certifies completeness and accuracy as of the revision date and commits to re-attesting affected sections within thirty days of a material change. Currency is 12 months from the revision date.

Level 2

Verified

Level 1, examined by a qualified verifier under the Part V methodology. The verifier authenticates documents, reconciles the device schedule against public FCC authorization records, confirms the definition texts are the texts in force, confirms supplier declarations directly with the declaring suppliers, and reconciles the corporate chain against registry filings retrieved within ninety days. The Annex F statement names what was examined, the Protocol version applied and the file revision covered. Currency is 12 months from the verification date.

Level 3

Monitored

Level 2, plus the standing change control of Part VI and annual re-verification. Nine classes of event are material changes, from a new production site to a Covered List addition touching an entity in the file, and each requires re-attestation of the affected sections within thirty days. Holders of a Conditional Approval add the quarterly onshoring evidence module of 3.3. Status is continuous, and lapses automatically if re-verification is missed.

Using the standard

Where to start.

The Protocol is written to be required by one party and satisfied by another, both working from the same published text.

Buyers and importers

Require a level of your vendors

Adopt the Protocol by reference and require a stated level and a current date as a condition of vendor qualification. The buyer’s kit carries the contract clauses, the vendor questionnaire and the file schemas under CC0.

Manufacturers

Document a non-covered position

A non-covered position rests on the coverage determination of 4.2 and the file sections behind it. The manufacturers’ page sets out what each section holds, what an officer signs on Annex A, and what a verifier examines.

The crosswalk maps the file to other regimes and standards. The regime profiles apply the same file to defense covered materials, defense batteries, unmanned aircraft systems, Section 889 and Build America, Buy America.

The comment docket lists the questions open for comment.

Questions on the Protocol

What is an Origin Evidence File?

It is the file a company holds behind a claim that its equipment is not foreign-produced. Part IV sets its eight sections, from device identity through component and corporate origin to the officer attestation that closes it. Every document carries a unique ID, and a master index maps each requirement to the documents satisfying it.

Source: Gatewell Protocol for Origin Evidence, Version 1.0, Part IV, clauses 4.1 to 4.8; clause 4.7.1.

Does the FCC require the Protocol?

No. The Commission requires an applicant certifying that a device is not covered equipment to be “able to have sufficient evidence that the device in question was not produced in a foreign country,” and its guidance states that “there is no specific documentation or evidence required.” The Protocol is a private standard written against that obligation. Conformity with it is not an FCC, DoW or DHS determination of any device’s regulatory status.

Source: FCC, Covered List FAQ on advanced robotic devices and power inverters, as retrieved September 8, 2026; Protocol Part VII.

Who can verify a file?

Any qualified verifier. Part II defines one as a party competent in supply-chain documentation and the Covered List regime, independent in judgment, who conducts the Part V methodology and discloses any assistance it provided in assembling the file under examination. That disclosure appears on the face of the Annex F statement. Verification is not reserved to Gatewell Group.

Source: Protocol Part II, definition of qualified verifier; Part V; Annex F, independence disclosure.

What does it cost to use?

Nothing. The text of the standard is published under CC BY 4.0, and the buyer’s-kit clauses, the vendor questionnaire and the file schemas under CC0. Buyers may adopt the Protocol by reference and require a stated level and current date as a condition of vendor qualification. A modified text may not be called the Gatewell Protocol; the designation and the conformity marks are reserved.

Source: Protocol Part VII; Version 1.0 license terms, Revision 2, September 17, 2026.

What may a conforming company say?

Part VII sets the sentence: “[Company]’s Origin Evidence File for [models] conforms to the Gatewell Protocol for Origin Evidence, Version 1.0, at Level [1/2/3], as of [date].” A claim names the level and the date. It may not extend to models outside the schedule, and it may not state or imply government endorsement.

Source: Protocol Part VII, claims of conformity.

Which equipment categories does it cover?

Unmanned aircraft systems and components, routers, power inverters, and advanced robotic devices, as of Version 1.0. A category added to the Covered List after this version comes within scope on publication of the matching Annex D deep-trace component matrix.

Source: Protocol clause 1.2.1; Annex D.

Does it set an origin threshold?

No. The Protocol prescribes evidence and procedure, and sets no ownership, content-percentage or origin threshold of its own. Every outcome standard is incorporated by reference from the governing Covered List entry, National Security Determination or Conditional Approval guidance as in force on the file’s revision date. Where a determination rests on the “foreign-produced” element, the file records the 48 CFR 25.101(a) position taken and its factual basis.

Source: Protocol clause 1.2.2; clause 4.2.3; 48 CFR 25.101(a).

What happens when the rules change?

The file is re-confirmed and the standard gives way. Clause 4.2.2 requires the current entry texts to be re-retrieved and every coverage determination re-confirmed at each revision date, with the retrieval evidenced. Files verified under a prior version remain valid to that version’s terms until their next re-verification, and the Protocol yields to any mandatory documentation standard on that standard’s effective date.

Source: Protocol clause 4.2.2; Part VII, maintenance.

How do I comment?

Write to protocol@gatewellgroup.com through October 31, 2026, or use the comment docket. Revision 2 closed the question this version had put on commercially available off-the-shelf items, the Commission having stated that the COTS exception is “inapplicable” to whether a device is a domestic end product and that COTS components are “still counted.” In its place Revision 2 asks how the component-cost test of 48 CFR 25.101(a) and eligibility for the credit at 26 U.S.C. 45X should be evidenced.

Source: Protocol clause 1.5; FCC, Covered List FAQ, as retrieved September 8, 2026; Version 1.0, Revision 2, September 17, 2026.

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© 2026 Gatewell Group. The text of the Protocol is published under Creative Commons Attribution 4.0 International. A modified text may not be called the Gatewell Protocol; the designation and the conformity marks are reserved. The buyer’s-kit clauses, the vendor questionnaire and the file schemas are released under CC0. Conformity is a documentation standard. It is not an FCC, DoW or DHS determination of any device’s regulatory status and guarantees no authorization outcome. Regulatory context verified against FCC sources as of September 16, 2026; the regime moves, so confirm current requirements before relying on any element of this document. This document is not legal advice.