FCC Covered List 2026: Logic-Bearing Components Hardware Founders Must Check Before the Next Prototype

Short answer: The FCC published final rule FR Doc 2026-18535 on September 11, 2026, with an effective date of October 13, 2026.

For new equipment authorization applications, the rule closes a component-part loophole when a device incorporates a logic-bearing hardware component produced by a Covered List entity and the device would be prohibited if that entity produced the whole device.

Connected-hardware teams should identify those parts, verify the legal producer, and lock acceptable alternates before the next functional prototype and PCB or module freeze.

The final rule is Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program. It is identified as FR Doc 2026-18535, 91 FR 57798, in ET Docket No. 21-232 and FCC 26-50. The rule was published September 11, 2026, and becomes effective October 13, 2026.

The core component provision appears in new 47 CFR 2.903(b)(2). It prevents authorization of a device that incorporates a logic-bearing hardware component produced by a Covered List entity when that device would itself be prohibited if the listed entity had produced the complete device.

The rule is prospective for new authorization applications. Previously authorized equipment is not affected. Applications pending on October 13, 2026 are exempt unless an amendment later adds, substitutes, or changes a logic-bearing component.

New 47 CFR 2.902 uses a bright-line standard drawn from the digital-device definition. A logic-bearing hardware component uses timing signals or pulses above 9,000 cycles per second and digital techniques, or uses RF energy for data processing. The practical question is whether the part carries out digital logic or RF data-processing work, not whether it is physically small or sold as a subassembly.

This is a screening distinction, not a substitute for reviewing the rule text and the current Covered List. A component name alone may not reveal the producer or the functions inside a module. Record both before deciding whether the rule changes an authorization plan.

The FCC distinguishes entries that identify a producer or provider from entries based on where a product was produced. The new component restriction applies to producer or provider-based Covered List entities. It does not apply to production-location-based entries, including location-based entries for foreign-produced unmanned aircraft systems or routers, unless the component producer is independently on the Covered List.

Do not use a distributor storefront, trading name, or module label as the only identity field. The check is about the producer or provider legal name and the exact basis for the Covered List entry.

Use these ten gates before the next connected-hardware prototype. The goal is to surface a disallowed or uncertain source while alternates can still be evaluated, not after a PCB, enclosure, test plan, or authorization strategy depends on it.

A logic-bearing component is often architecture-bearing too. Replacing a microcontroller, radio module, modem, FPGA, or digitally controlled power component can affect pinout, board area, power rails, antenna layout, thermal behavior, firmware interfaces, test fixtures, and lead-time assumptions. That makes the BOM review a prototype planning task, not only a filing-stage task.

For connected products, place the review beside the technical supplier record used by the electrical team. Our IoT product development and electronic product prototyping guide pages show where architecture, module selection, PCB work, and functional testing fit in the broader development path.

When a medical device is involved, keep this FCC equipment-authorization question separate from device cybersecurity and quality-system work. Review the FDA medical device cybersecurity checklist, the FDA QMSR 2026 guide, and our medical device prototyping capabilities only where those requirements apply.

The final rule also requires Covered List entities to use full certification, rather than a permissive change or Supplier Declaration of Conformity path, for modifications.

It adds online-marketplace FCC ID display obligations at the point of sale, with compliance dates of March 1, 2027 and June 1, 2027 depending on the applicable title and access requirement. The rule also revises the critical-infrastructure definition used for Covered List entries based on how equipment is used.

These provisions affect different actors and timelines. Keep them in the compliance plan, but do not let them obscure the immediate prototype question: who produced each logic-bearing component in the configuration intended for a new authorization application?

If your next prototype includes connected modules, radios, programmable logic, or digitally controlled subsystems, LA NPDT can help turn this checklist into an engineering-ready BOM review, architecture plan, and alternate-source decision before PCB or module freeze. Start with product development consulting or apply to partner with us for a focused project discussion.