Covered List Update and Conditional Approval Overview
On March 20, 2026, the Federal Communications Commission updated its Covered List to encompass routers produced by foreign countries. This designation prohibits such covered equipment from receiving FCC equipment authorization unless a specific determination is granted by the Department of War (DoW) or the Department of Homeland Security (DHS).
The guidance document outlines the individualized assessment process through which router manufacturers can request a Conditional Approval. If granted by DoW or DHS, the conditional approval exempts the producer from Covered List restrictions for periods of up to 18 months by establishing that the equipment does not pose unacceptable risks to U.S. national security or the safety and security of U.S. persons.
- Covered List designation applies to routers produced by foreign countries as of March 20, 2026.
- Authorizations require risk determinations from the Department of War or the Department of Homeland Security.
- Conditional Approvals are granted for periods of up to 18 months based on agency discretion.
Required Corporate Structure Disclosures
To apply for a Conditional Approval, manufacturers must submit comprehensive corporate governance and ownership information. Submissions must include a formal certification signed by an authorized corporate officer confirming that all details are accurate, complete, and subject to prompt disclosure upon any material change.
Applicants that materially misrepresent information or violate approval terms face immediate termination of their approval and will be barred from applying again in the future.
- Legal name, jurisdiction of incorporation, and principal place of business.
- Complete ownership hierarchy including parent companies, subsidiaries, affiliates, and joint ventures.
- Identification of all beneficial owners holding a five percent or greater equity stake.
- List of executive leadership and board members, noting nationalities and countries of residence.
- Full disclosure of foreign government ownership, control, influence, financing, or material support arrangements.
Manufacturing and Supply Chain Disclosures
Applicants are required to provide granular supply chain transparency for the specific router models subject to the request. This includes design provenance, component sourcing, and contingency planning for critical inputs.
- A detailed bill of materials for the router seeking conditional approval.
- Country of origin for all components, router design, onboard software, and firmware.
- Identification of entities holding intellectual property ownership and managing software updates.
- Justification explaining why the device is not manufactured in the United States, why foreign sources were selected, and whether alternatives exist.
- Specific geographic locations for manufacturing, final assembly, and testing.
- Quantitative assessment of supply chain concentration by country as a percentage of total value and production volume.
- Identification of single points of failure, sole-source suppliers, their countries of origin, and contingency plans.
U.S. Manufacturing and Onshoring Plans
Applicants must submit a time-bound commitment to establish or expand domestic manufacturing capacity in order to qualify for standard FCC equipment authorization.
The applicant must assign a dedicated point of contact or office responsible for oversight and implementation. This designated office must provide quarterly status updates to the agency that issued the Conditional Approval.
- Detailed, time-bound plan to establish or expand U.S. manufacturing for the covered router.
- Designation of a responsible corporate office or contact required to file quarterly progress reports.
- Description of current U.S. assembly, component percentages, headcount, and facility locations.
- Committed and planned capital expenditures or financing dedicated to U.S. manufacturing over the next one to five years.
- Progress inventory on onshoring plans submitted under any prior or existing conditional approvals.
Agency Contacts and Submission Details
Submissions do not guarantee approval, and all final determinations remain at the discretion of the reviewing agencies. The agencies may request supplemental information as needed during the evaluation process.
Entities seeking to submit applications or inquire about conditional approvals may contact the designated FCC coordination channels.
- Conditional Approval Submissions: Conditional-approvals@fcc.gov
- Covered List Inquiries: Chris Smeenk (chris.smeenk@fcc.gov)