FCC Expands Covered List to Include Foreign-Produced Routers

Bottom Line Up Front

Building on its recent Covered List updates in December 2025 and January 2026, the Federal Communications Commission (FCC) issued another significant action on March 23, 2026, adding certain consumer-grade routers produced in foreign countries. This update reflects the FCC’s expanding national security–focused regulation of communications equipment under the Secure and Trusted Communications Networks Act of 2019, and it may limit the ability of affected companies to obtain equipment authorization, import, market, or sell such devices in the United States.

Analysis

As we previously reported (in January 2026 and December 2025), the FCC’s Covered List identifies communications equipment and services deemed to pose an unacceptable risk to US national security. Equipment placed on the Covered List is subject to significant restrictions, including limitations on authorization, importation, marketing, and sale within the United States.

On March 20, 2026, the FCC received a national security determination (NSD) regarding the unacceptable risks posed by routers produced in foreign countries. Specifically, the NSD concluded that consumer-grade routers made outside the United States carry supply chain and cybersecurity risks that could be exploited to disrupt the economy, critical US infrastructure, and national security. In response, on March 23, 2026, the FCC expanded its Covered List to include foreign-produced routers, except routers that “have been granted a Conditional Approval” by the U.S. Department of War or the U.S. Department of Homeland Security.

The FCC adopted the definition of “routers” from the National Institute of Standards and Technology’s Internal Report 8425A, describing them as “consumer-grade networking devices that are primarily intended for residential use and can be installed by the customer.” Under the NSD, a router is considered “produced in a foreign country” if “any major stage of the process through which the device is made, including manufacturing, assembly, design, and development” occurs outside of the United States. The nationalities of the entities producing routers is not relevant to whether such routers are considered to be “produced in a foreign country.”

Adding foreign-produced routers to the Covered List means that the FCC will no longer grant equipment authorizations for new models of consumer routers produced in a foreign country. Without such authorization, new devices generally cannot be legally imported, marketed, or sold in the US. However, this action neither affects routers that have already received FCC authorization and are currently available on the market nor prohibits their ongoing use by consumers.

Key Takeaways

Companies should focus on the following key steps to manage compliance and mitigate risks arising from the FCC’s latest Covered List update:

• Conduct a thorough assessment of products and supplier relationships to identify any items potentially impacted by the FCC’s Covered List.
• Confirm whether equipment has FCC authorization and determine which products may be restricted under the new rules.
• Stay informed on future Covered List updates, as this will be critical for navigating this evolving regulatory landscape.

The FCC’s inclusion of foreign-produced consumer routers on the Covered List marks a significant regulatory development with immediate implications for the US communications market. Companies, including those contracting directly or indirectly with the federal government, that are involved in the manufacture, import, or distribution of affected routers should carefully review their operations, ensure compliance with FCC requirements, and evaluate strategies to mitigate potential market and supply chain disruptions.

Goodwin’s Government Contracts & Grants team has significant experience counseling clients engaged in the manufacture and sale of communications equipment. They also have extensive expertise in helping clients navigate the rapidly changing laws and regulations that impact these activities. Please contact the authors of this alert or the Goodwin lawyer whom you regularly work with if you have questions.

This informational piece, which may be considered advertising under the ethical rules of certain jurisdictions, is provided on the understanding that it does not constitute the rendering of legal advice or other professional advice by Goodwin or its lawyers. Prior results do not guarantee similar outcomes.