The United States has begun extending domestic content requirements into product categories that were never regulated this way before. On July 28, 2026, the Federal Communications Commission added foreign-produced advanced robotic devices to its Covered List, which means new mobile robots that do not qualify as "domestic end products" can no longer receive the equipment authorization required to sell them in this country. Under this guidance, a robot counts as domestic only if it is manufactured in the United States and more than 65% of its component cost is domestic, a threshold that rises to 75% in 2029 under the Buy American standard the rule adopts.
For robotics manufacturers, the operative word is "component." Nothing in the rule prohibits a Chinese actuator or a Korean battery pack individually. What the rule does is convert every line of the bill of materials into a compliance variable, and it treats a component of unknown origin as foreign. A company that cannot document where its parts come from has a market access problem. Visibility has become a condition of sale.
Best practices in a rising-content environment
The 65% figure is not the end state. Content thresholds have moved in one direction for a decade, across administrations, and by all appearances they will continue along that vector for the foreseeable future. Supply chain strategy therefore must be built for a rising bar rather than for the current one. There are three practices that matter most.
- Know the country of origin of every component, not just of every supplier.
Most manufacturers know who they buy from. Far fewer know where a tier-one supplier's motors, magnets, and controllers were actually produced, and the rule counts cost at the component level. Origin data needs to sit next to price and lead time in the item master and on the approved supplier list, and it needs to be maintained as suppliers change their own sources.
- Qualify domestic alternatives before you need them.
A domestic source that is identified, quoted, and first-article approved is an option you can exercise. A domestic source you have never contacted is a name on a list. The difference between the two is measured in months.
- Design for a second source.
Engineering decisions made for performance and cost are now also content decisions. Where a design can accept a slightly heavier motor or a different reducer geometry, it should, because a wide set of qualified sources is sound protection against a threshold that moves.
Sourcing the parts that are hard to find
In practice, this can be very difficult to execute. Actuators are often the largest single line in a humanoid robot’s hardware BOM, and much of the world's supply of batteries, lidar, and motor controllers for robots is produced in China. Inside the actuator sit the components that are hardest to replace: strain-wave and cycloidal reducers, frameless torque motors, precision ball screws, and the rare-earth permanent magnets that make compact motors possible. American capacity exists for several of these, but it is scarce and often pre-ordered far in advance.
We built Sustainment in part to solve the search problem. There are roughly 284,000 manufacturing establishments in the United States according to the Census Bureau, and the vast majority are small firms that have limited marketing presence and can be difficult to find. Supplier discovery tools can surface the gear shop or motor winder that a robotics company would never otherwise encounter, but a tool can only find capacity that exists. For certain reducers and magnet grades, domestic supply is scarce in absolute terms, and no amount of discovery changes the math of a gear manufacturer with three customers and one open slot. Supply chain teams at American robotics manufacturers should expect the next several years to be defined by qualification backlogs, price premiums, and difficult conversations with engineering. These are structural pressures that will compound over time.
Robotics is not an exception to the rule
It is also important to think beyond robotics. The FCC has applied origin-based restrictions to drones, consumer routers, power inverters, and mobile robots in the space of eight months. The Commerce Department's connected vehicle rule takes hold with model year 2027, and Congress is moving to extend it, and a federal procurement prohibition on certain Chinese semiconductors takes effect in December 2027. The pattern is consistent, and regulators will continue to use these policies to drive demand to American suppliers.
Our view is that the same logic will reach several adjacent industries within the next six to eighteen months. With high confidence, we expect stationary industrial robots, which the current determination expressly excludes, to be brought inside the FCC definition. We expect energy storage systems and their battery cells to follow the inverter listing, since the grid security rationale is identical. We expect connected agricultural and construction equipment and building control systems to see either FCC action or content requirements attached to federal and state procurement. Medical robotics is carved out today, and we would not count on that carve-out surviving indefinitely.
If you build robots, this is now your operating environment. If you do not, it could be a preview of yours, and the companies that begin mapping component origin and qualifying domestic sources this year will be the ones with options when their category is named. The regulatory bar will likely rise faster than domestic capacity can be built to meet it. Fortunately, a great deal of that capacity already exists in American shops that are simply hard to find, and finding them is work that can begin today.