Update 1: The firmware waiver (DA 26-789)

This one came out the same day and almost nobody covered it, which is a shame because it’s the one that touches the robot in your house.

Under normal FCC rules, once equipment lands on the Covered List, there are restrictions on the kinds of changes a manufacturer can push to an already-authorized device. That would include a lot of routine software and firmware updates.

The FCC’s Office of Engineering and Technology waived those restrictions for this situation. Devices that were authorized before the July 28 Covered List addition may continue to receive software and firmware updates that “mitigate harm to U.S. consumers” — the notice specifically calls out updates that patch vulnerabilities and keep devices compatible with different operating systems — at least until January 1, 2029.

Two things to keep straight: the waiver allows updates, it doesn’t require a company to keep supporting an old model. And what happens after that date isn’t settled. The FCC has extended a similar waiver before in the router context, but there’s no announcement about extending this one. I’ll report it if it happens; I won’t guess.

Update 2: The Conditional Approval process

This is the door that’s open for manufacturers, and the guidance for it was released alongside the FCC’s announcement.

Here’s how it works. A company that builds robots overseas can ask for a determination that a specific robot, or a whole class of its robots, does not pose an unacceptable national security risk. If the government makes that determination and passes it to the FCC, those products can keep getting equipment authorizations even though the category is on the Covered List.

For robots, only the Department of War can grant it. (For power inverters, either the Department of War or Homeland Security can.)

It is a substantially bigger lift than a normal FCC filing. Here’s what the guidance asks for:

Applications are due by January 1, 2028, must be submitted as a machine-readable PDF, and the Department may ask for more information during review. Submitting is not the same as getting approved. The guidance states decisions are final and entirely at the Department’s discretion.

Update 3: The other exit — build it here

There’s a second way out that doesn’t involve any application at all. If a robot qualifies as a “domestic end product,” it isn’t foreign-produced, so it never falls under the Covered List entry in the first place.

The bar for that is the Buy American standard at 48 CFR § 25.101(a): the product has to be manufactured in the United States, and the cost of its domestic components has to exceed 65% of total component cost. That percentage is scheduled to step up in later years, so it’s a moving target.

That’s a real number companies can measure a bill of materials against. Right now, very few robot vacuums sold in the U.S. would clear it — Matic is one of the few companies that says it builds its robot vacuums here.

Update 4: What the FCC’s FAQ cleared up

The FCC posted a FAQ page that answered several things people were arguing about online. Straight from it:

• The nationality of the company producing the device is not relevant to whether a device counts as foreign-produced. The FCC states the action is country neutral.
• Importation, marketing or sale to the federal government or federal agencies is entirely exempt from these Covered List restrictions.
• Companies may still import small batches of unauthorized devices strictly for product development or testing, as long as they aren’t marketed or sold.

Every date in one place

What still isn’t answered

I’d rather tell you what I don’t know than fill the gaps with guesses. Here’s the open list:

• No Conditional Approval has been publicly granted for a robot vacuum yet.
• There’s no published timeline for how long a review takes.
• The firmware waiver past January 1, 2029 hasn’t been addressed.
• No manufacturer has publicly confirmed a specific U.S. product change tied to this rule.
• It isn’t clear how models that were announced but not yet authorized will be handled.

This is a fast-moving story and there’s a decent chance something changes the week after I publish this. That’s why I’m keeping all four of these articles updated rather than writing one and walking away.

Sources

• FCC Public Notice DA 26-786 (July 28, 2026)
• FCC Office of Engineering and Technology waiver DA 26-789
• Department of War Conditional Approval guidance for advanced robotic devices
• FCC, “FAQs on Recent Updates to FCC Covered List Regarding Foreign-Produced Advanced Robotic Devices and Power Inverters”
• Vacuum Wars — “Conditional Approval for FCC Authorization: What’s the Process for New Foreign-Produced Robot Vacuums?”
• Cooley, Wiley, Akin Gump and Morgan Lewis client alerts on the Covered List additions
• Consumer Reports and Tom’s Hardware — domestic end product threshold reporting

Accurate as of August 5, 2026.