Background on Covered List Update for Power Inverters
On July 27, 2026, the Federal Communications Commission (FCC) updated its Covered List to include foreign-produced power inverters. As a result of this action, such covered equipment is prohibited from receiving an FCC equipment authorization unless a specific determination is made by the Department of War (DoW) or the Department of Homeland Security (DHS).
An exemption from these Covered List restrictions can be granted if DoW or DHS determines that a specific power inverter device or class of power inverters does not pose unacceptable risks to U.S. national security or the safety and security of U.S. persons. The FCC issued Annex A guidance outlining the requirements for producers seeking this Conditional Approval through an individualized risk assessment.
Conditional Approval Application Process and Deadlines
Producers seeking Conditional Approval must compile all requested disclosures into a machine-readable PDF and submit it to Conditional-approvals@fcc.gov. Submission of an application does not guarantee approval, and DoW and DHS retain final discretion on all decisions.
Applicants must submit their Conditional Approval applications by January 1, 2028. Each application must include a formal certification by an authorized corporate officer confirming that all provided information is complete and accurate, with a commitment to promptly disclose any material changes. Material misrepresentations or violations will lead to termination of the approval and bar the applicant from reapplying.
- Application submission deadline: January 1, 2028
- Submission format: Machine-readable PDF sent to Conditional-approvals@fcc.gov
- FCC Covered List contact: Chris Smeenk (chris.smeenk@fcc.gov)
Required Corporate Structure Disclosures
Applicants are required to provide extensive details concerning their ownership, governance, and foreign ties to facilitate national security reviews.
- Legal name, jurisdiction(s) of incorporation, and principal place of business.
- Complete ownership structure, including parent companies, subsidiaries, affiliates, and joint ventures.
- Beneficial owners holding five percent or greater equity.
- Board members and executive leadership, including their nationality and country of residence.
- Any foreign government ownership, control, influence, financing, or material support, including arrangements allowing foreign persons or governments to influence operations, decision-making, or access to technology.
Manufacturing and Supply Chain Disclosures
The guidance requires transparent disclosure regarding the supply chain, components, and software origins for the subject power inverter.
- Detailed bill of materials for the power inverter device.
- Country of origin for all inverter components and for the design of the inverter.
- Entities responsible for intellectual property (IP) ownership and software updates.
- Justification explaining why any foreign inverter is not currently manufactured in the United States, including why foreign sources were chosen and whether alternatives exist.
- Locations of manufacturing, final assembly, and testing.
- Country of origin for any onboard software and firmware.
- Quantitative assessment of supply chain concentration by country, expressed as both a percentage of total value and production volume.
- Identification of single points of failure, including sole-source suppliers, their countries of origin, and contingency plans if those suppliers become unavailable.
U.S. Manufacturing and Onshoring Plan Requirements
To qualify for an FCC authorization under a Conditional Approval, applicants must establish a commitment to domestic production through a comprehensive U.S. manufacturing and onshoring plan.
- A detailed, time-bound plan to establish or expand manufacturing in the United States for the power inverter device.
- A dedicated point of contact or office responsible for overseeing the onshoring plan, required to submit quarterly progress updates to the issuing agency.
- A description of existing U.S.-based manufacturing and assembly, including the percentage of components assembled domestically, current U.S. headcount, and facility locations and functions.
- Planned and committed capital expenditures, financing, or other domestic manufacturing investments over the next 1 to 5 years, including hiring targets, facility expansions in square feet, and milestone timelines.
- An inventory of progress made on previously submitted U.S. onshoring plans if applying for an extension or holding other existing covered Conditional Approvals.