Questions buyers ask
Does the FCC require buyers to do this?
No. The duty sits on the applicant for equipment authorization, who certifies in writing that the equipment is not prohibited under 47 CFR 2.903 and must hold sufficient evidence behind it. The Commission prescribes documentation for neither of you.
Source: 47 CFR § 2.911(d)(5); FCC Covered List FAQs, retrieved September 8, 2026.
Is a vendor's FCC ID enough?
Not by itself. An FCC ID identifies a grant of certification, which stays effective until it is set aside, revoked, withdrawn, rescinded or surrendered, or the Commission establishes a termination date. It rests on the applicant's own signed certification, behind which the Commission requires no particular evidence. A false covered-equipment certification is the predicate for revocation under 47 CFR 2.939(d), exercised in August 2026 against Odyssey Robot LLC.
Source: 47 CFR §§ 2.911(d)(5), 2.927(a), 2.939(d); Order of Revocation DA 26-839, August 11, 2026.
What about models authorized before the category was listed?
The grant stands. Equipment authorizations do not expire and there is no renewal procedure, so a certification granted before a category was listed remains valid.
Two limits belong in the answer. Importation and marketing of previously authorized covered equipment can be shut off under 47 CFR 2.939(e) without revoking the authorization, which happened for equipment listed in 2024 or earlier, effective July 16, 2026. Covered equipment is also excluded from the permissive-change procedures at 47 CFR 2.932(b) and 2.1043(b), which closes off hardware changes absent a waiver. Software and firmware updates that mitigate harm to consumers are permitted by waiver until at least January 1, 2029.
Source: 47 CFR §§ 2.927(a), 2.932(b), 2.939(e), 2.1043(b); DA 26-635, 91 FR 41023; DA 26-789, July 28, 2026.
Does this replace our Section 889 representations?
No. Section 889 travels through its own FAR machinery, and an offeror's representation under 48 CFR 52.204-24 answers a different question from the one the Covered List asks. Our crosswalk maps the file against each regime.
Source: 48 CFR §§ 4.2105, 52.204-24, 52.204-25.
May we change the clauses, and what does this cost?
The clause language and the questionnaire are dedicated to the public domain under CC0 1.0, with no attribution condition, so change what you like. The standard itself is published under CC BY 4.0; a modified text may not be called the Gatewell Protocol, and the designation and marks are reserved. Requiring it costs nothing. The Protocol is free to use, to cite and to require of counterparties.
Source: Gatewell Protocol, Version 1.0, status statement and licence terms.
How do we check a vendor's claim?
Start with the sentence. A claim must name the level and the date and may not reach models outside the schedule, so one missing either is not a claim under the Protocol. At Level 2 or 3 the Annex F statement identifies the verifier, the version applied and the revision examined, and carries an independence disclosure.
The registry lists verifications issued under the Protocol. Verification under Version 1.0 opens with the final text, so it holds no entries until then.
Source: Gatewell Protocol, Version 1.0, Parts V and VII; Annex F.
Put it in the next solicitation.
The clause set goes into an RFP as written, with the level and the currency period filled in. The standard, with every annex a vendor works from, is at Version 1.0.
To have a vendor bench assessed against the Protocol, request a diagnostic.