The FCC Covered List requirements have entered a new enforcement stage in the United States. On October 22, 2026, the Federal Communications Commission (FCC) announced that its Office of Engineering and Technology (OET) had prevented two devices—a dashboard camera and a wireless video transmitter—from being marketed or sold in the country.
According to the FCC, each device contained a chip produced by an entity included on the Covered List. The action represents the first enforcement case under rules that took effect on October 13, 2026, concerning logic-bearing, or “smart,” components produced by Covered List entities.
FCC Covered List Rules Applied to Device Components
Under the rules effective October 13, equipment authorization applicants must attest that their devices do not contain covered logic-bearing components.
The FCC did not disclose the manufacturers, device models, or chip part numbers involved in the October 22 action. Industry commentators believe the components may have been identified through internal photographs submitted as part of the certification filings. However, the FCC announcement itself did not confirm how the components were detected.
Therefore, manufacturers should carefully review the origin and producer of processors, systems-on-chip (SoCs), chipsets, modules, and other logic-bearing components before submitting an equipment authorization application.
Additionally, supplier declarations, internal photographs, bill-of-material information, and applicant attestations should remain consistent throughout the filing process.
Existing FCC Authorizations Remain Valid
The new requirement applies going forward rather than retroactively.
Equipment authorized before October 13, 2026, retains its existing authorization. Likewise, applications that were already pending on that date remain exempt from the new requirement unless a logic-bearing component is subsequently added or changed.
Consequently, companies should distinguish between previously authorized products, applications already pending as of the effective date, and new or modified applications subject to the component restrictions.
What Manufacturers Should Consider
The first enforcement action demonstrates that component sourcing now plays a direct role in FCC equipment authorization compliance.
Manufacturers preparing new applications should confirm the producer of every logic-bearing component before filing and maintain appropriate supplier documentation. Moreover, information submitted across certification materials should accurately support the applicant’s attestation regarding Covered List components.
The FCC stated that it intends to continue enforcing the FCC Covered List component rules aggressively.
Companies monitoring U.S. regulatory requirements can follow developments affecting equipment authorization and market access through Entirety’s Global Regulatory Updates Service.
Regulatory Impact Assessment
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Technical Standards?
No -
Type Approval & Market Access?
Yes -
Imports, Customs, Trade, or Market Surveillance?
Yes -
Spectrum Management?
No
