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Power Inverters on the FCC Covered List

  • Aug 7
  • 6 min read

Updated: Aug 27

Central inverter and module rows at a utility-scale solar site.

Photo: Dalton Huston-Bursaw / U.S. Department of Energy


On July 28, 2026, the FCC's Public Safety and Homeland Security Bureau added foreign-produced power inverters — and advanced robotic devices — to the Covered List, implementing two National Security Determinations transmitted by a White House-convened interagency body the day before.


Key takeaways

  • Covered equipment cannot receive a new FCC equipment authorization, which is required before import, marketing, or sale. Authorizations granted before July 28, 2026 remain valid, and nothing requires removal of equipment already installed.

  • Three conditions must all hold: power conversion, remote connectivity, and foreign production under the FAR domestic end product test.

  • Owners carry no direct compliance duty, but the exposure reaches them through the supply chain — vendor viability, spares, firmware, and substitution risk.

  • Solar and storage account for roughly four-fifths of planned 2026 utility-scale additions, so the affected category is most of what is being built.


Why this reaches most of the build


EIA's generator inventory data published February 20, 2026 puts 2026 utility-scale capacity additions at a record 86 GW, with solar at 51% and battery storage at 28% — close to four-fifths of the planned build is inverter-based, before distributed and behind-the-meter systems are counted. Remote monitoring and control are standard on modern grid-connected inverters, and connectivity is one of the conditions that brings a unit into scope. The category the listing reaches is not a niche.


For what that networked layer means in distributed portfolios, see Cybersecurity for Behind-the-Meter Platforms.


How the restriction works


The Covered List sits in communications law rather than energy regulation, and its operative effect is narrow but hard. Covered equipment cannot receive an FCC equipment authorization, and every applicant for an authorization must certify that its equipment is not covered.


Because most devices that emit radiofrequency energy need an authorization before they can be imported, marketed, or sold, the listing functions as a gate on market entry. 

The restriction turns on the authorization date, not on deployment status. Authorizations granted before July 28 remain valid, so those models may still be imported, sold, and installed. Units already installed are unaffected, and nothing in the notice restricts operation.


The same mechanism produced two earlier listings — uncrewed aircraft systems in December 2025 and routers in March 2026 — and advanced robotic devices were added the same day as inverters. Each rested on its own determination. There is no general rule capturing connected equipment.


What makes an inverter covered

A unit is covered only if all three conditions hold. Fail any one and it sits outside the listing. The notice names microinverters, string, central, and hybrid inverters as examples rather than as a closed list, so an unnamed device type is not outside the definition by default.


Figure 1. The three conditions that determine whether a unit is covered.
Figure 1. The three conditions that determine whether a unit is covered.


Condition 3 is where most of the analysis sits. Foreign-produced means the article fails the domestic end product test at 48 C.F.R. § 25.101(a), which has two parts: the article must be manufactured in the United States, and the cost of domestic components must exceed 65% of total component cost for items delivered through 2028, rising to 75% from 2029.


The threshold is measured on component cost — domestic components as a share of the cost of all components — not on labor, value added, or final assembly. Production and content decide exposure, not corporate nationality. A U.S.-headquartered manufacturer producing offshore is captured; a foreign-owned manufacturer meeting the test is not.


One point invites argument, because the FAR itself waives the component test for off-the-shelf items in federal acquisitions. The Commission's Covered List FAQs address it head-on: that exception is “inapplicable to whether a device is a domestic end product” under section 25.101(a), and all components, off-the-shelf ones included, must be counted.


Who already manufactures in the United States

Several manufacturers have announced domestic production. Enphase produces IQ microinverters and batteries in South Carolina and Texas, and on August 4 reinforced that commitment across residential, commercial, and data center power electronics. SolarEdge reports in its FY2026 10-Q that it manufactures the vast majority of its products in the United States — inverters in Texas, power optimizers and inverters in Florida, batteries in Utah — having discontinued production in China, Mexico, and Hungary.


Those claims are made against the IRA domestic content bonus, a Treasury test with its own thresholds and methodology. That is not the test the FCC has adopted. As of publication, no manufacturer has publicly claimed to satisfy the FAR domestic end product standard as the FCC applies it, and U.S. assembly alone does not establish it — the domestic component cost threshold is the binding part, and it is measured on the article, not the corporate footprint.


What the listing does not reach


For entity-based listings such as Huawei and ZTE, Covered List status pulls in a wider set of federal consequences. The Commission stated that those do not attach here, because this equipment is identified by place of production rather than by entity.


Two exceptions also remain. Models authorized before July 28 may still be imported, sold, and installed, and the Commission has confirmed that previously purchased devices are unaffected. That status attaches to the authorization rather than to inventory, so a model developed or stocked before July 28 that had not yet been authorized does not qualify — worth confirming at the FCC ID level. Producers may seek Conditional Approval from the Department of Defense — which the notice refers to by its secondary title, the Department of War — or the Department of Homeland Security. Either route requires a plan to establish or expand U.S. manufacturing.


Figure 2. The two exceptions, and the limits on what the listing reaches.
Figure 2. The two exceptions, and the limits on what the listing reaches.


Where the exposure lands

For owners and developers the consequence runs through the supply chain, not through liability. A vendor that cannot authorize new models stops refreshing its line, so buyers specify from a frozen catalog and carry vendor-continuity risk on spares and warranty service across a 25-year asset life — the permissive-change waiver that allows an authorized model to be updated covers software and firmware, not hardware. Substituting mid-project reopens equipment schedules and can trigger interconnection re-study. And authorization status is now a diligence item in financing and M&A that did not exist in July.


None of this requires the buyer to have done anything wrong. The formal duty runs to sellers, and the marketing prohibition reaches sale, lease, offer, import, and distribution — so a party that imports directly, leases equipment on, or distributes it sits inside that set. A developer that simply installs an authorized unit bought from a domestic distributor does not. 


Two sourcing regimes now run in parallel and are easy to conflate. Foreign Entity of Concern (FEOC) material assistance rules gate tax credit eligibility; the FAR domestic end product test gates equipment authorization, and therefore market entry — not use of equipment already lawfully acquired. Different agencies, different tests, different clocks, and a unit can satisfy one while failing the other.


Key dates

Date 

Event 

Dec 22, 2025 

Uncrewed aircraft systems added to the Covered List 

Mar 23, 2026 

Routers added 

Jul 27, 2026 

National Security Determinations transmitted to the FCC 

Jul 28, 2026 

Power inverters and advanced robotic devices added; effective on release 

Jan 1, 2028 

Deadline for Conditional Approval applications (set by the Annex A guidance, not the Public Notice) 

Through Dec 31, 2028 

Domestic content threshold of 65% applies 

Jan 1, 2029 

Domestic content threshold rises to 75% 

Jan 1, 2029 

Earliest the OET software and firmware permissive-change waiver could lapse; DA 26-789 runs “at least until” this date 


The listing took effect on release, and there is no grace period for new covered models. January 1, 2028 is the deadline to file for Conditional Approval, set by the Annex A guidance rather than the Public Notice itself. It is not a transition date: the restriction operates in full from July 28, 2026, and filing neither guarantees approval nor suspends it.


What to watch


  • Conditional Approval throughput at DoD and DHS; prior listings produced application backlogs.

  • A pending FCC rulemaking proposing the domestic end product standard across all Covered List entries.

  • Whether any manufacturer publicly claims to meet the FAR domestic end product standard, as distinct from the IRA domestic content bonus.


The action does not change what is installed or under construction. It changes what can be specified.

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© 2026 Simcore Partners LLC, including its subsidiaries and affiliates, is a consulting firm and not a certified public accounting firm or a law firm. All Rights Reserved.

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