FCC Covered List Component Enforcement: 2 Devices Blocked
FCC Covered List Component Enforcement Begins: OET Blocks Two Devices With HiSilicon Chips
FCC Covered List component enforcement is no longer theoretical. On 22 October 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 United States. Both contained a chip produced by HiSilicon, a Huawei subsidiary and a Covered List entity. The FCC called it the first enforcement action under its component rules, which took effect on 13 October 2026.
Background: the FCC component rule
For years the FCC has refused to authorize equipment produced by entities on its Covered List. Until this autumn, though, an otherwise compliant device could still be authorized if a Covered List entity only made one of its parts. The FCC closed that gap in its Third Report and Order (FCC 26-50, ET Docket No. 21-232), adopted on 22 July 2026 and published in the Federal Register on 11 September 2026. The rules took effect on 13 October 2026.
GMA Labs explained the rule and the new online marketplace obligations in September. What's new now is that OET has applied it to real products, nine days after it took effect.
Key Changes in the FCC Covered List Component Enforcement Picture
What the FCC did
According to the FCC's release, OET acted after finding that both device models contained a HiSilicon chip. The FCC notes that HiSilicon markets that chip for the surveillance market with built-in face detection. Chairman Brendan Carr said the FCC would keep acting to enforce the component rules. The release doesn't identify the manufacturers, the model numbers or the FCC IDs involved.
What the rule covers
Under the amended 47 CFR 2.903(b), a device can't be authorized if it includes a logic-bearing hardware component produced by a Covered List entity and the device would have been prohibited had that entity made the whole product. The definition of a logic-bearing hardware component is broad: devices, systems, modules, sub-assemblies, integrated circuits and other physical parts that use digital techniques, including those that process, store or transfer data. Purely mechanical or passive parts, such as housings, fasteners, resistors, wiring and plain battery cells, aren't covered. Software and firmware aren't covered for now.
Who's already protected
The rule applies to new applications. Existing grants aren't affected, and applications pending on 13 October 2026 can continue unless they're amended to add, substitute or change a logic-bearing component. Modifications to equipment produced by a Covered List entity need a full new certification rather than a permissive change.
What This Means for Manufacturers
Component sourcing is now part of FCC approval. The first two cases involved a camera and a video transmitter, but the rule applies to any device that needs FCC authorization.
Applicants should know who made every logic-bearing part: processors, SoCs, chipsets, memory, radio modules and sub-assemblies.
A product change after 13 October 2026 that swaps a logic-bearing part can pull a pending application into the new rules.
Video and imaging products using low-cost camera SoCs deserve an early review, given where enforcement started.
Retail and e-commerce partners will soon have their own obligations, with FCC ID display required from 1 March 2027 or 1 June 2027 depending on the platform type.
Certification Impact Summary
Area | Before | After | Impact level |
Products made by Covered List entities | Not authorized | Not authorized (unchanged) | Low |
Devices with a Covered List logic-bearing part | Could be authorized | Not authorized from 13 October 2026; first devices blocked 22 October 2026 | High |
Passive and mechanical parts, software, firmware | Not restricted | Not restricted for now | Low |
Existing grants | Valid | Remain valid | Low |
Applications pending on 13 October 2026 | Prior rules | Prior rules, unless a logic-bearing part is added or changed | Medium |
Supply chain documentation | Not reviewed for components | Component origin needs to be known and documented | High |
Timeline and Required Actions
Key Dates
Date | Milestone |
22 July 2026 | FCC adopts the Third Report and Order (FCC 26-50) |
11 September 2026 | Rules published in the Federal Register |
13 October 2026 | Component rules take effect |
22 October 2026 | FCC announces first enforcement: two devices blocked |
1 March 2027 | FCC ID display required for marketplaces that sell directly or hold title |
1 June 2027 | FCC ID display, verification and seller certification for third-party-only marketplaces |
Required Actions for Manufacturers
Build a bill of materials view that lists the producer of every logic-bearing component.
Check those producers, and their subsidiaries and affiliates, against the FCC Covered List.
Get written origin statements from suppliers for chipsets, SoCs, modules and memory.
Review pending applications before amending them, since changing a logic-bearing part brings in the new rules.
Keep internal photos, block diagrams and parts lists consistent across the application file.
Agree with your TCB how component origin will be documented in new filings.
Conclusion
The FCC has shown it will check what's inside a product, not only who sells it. Manufacturers that map component origin now will avoid stalled applications and blocked products later. Contact our team for help reviewing your US equipment authorization files.
