On October 22, 2026, the Federal Communications Commission (“FCC”) announced its first enforcement action under new rules that prohibit FCC authorization of certain devices incorporating “logic-bearing hardware components” produced by entities identified on the FCC’s Covered List. The rules took effect less than two weeks earlier on October 13, with the prompt action signaling the FCC’s willingness to enforce the new component-level restrictions. This action is only the latest in the FCC’s series of actions to enforce the Covered List and its national-security rules, underscoring that space as a continued enforcement priority.
The FCC’s Office of Engineering and Technology prevented two devices, a dashboard camera and a wireless video transmitter, from being marketed or sold in the United States after determining that the devices contained a chip produced by HiSilicon, a subsidiary of Huawei. The FCC stated that HiSilicon advertises the chip as “designed for the surveillance market” and as incorporating “detection algorithms for human faces.” Huawei is on the Covered List for specified telecommunications and video-surveillance equipment and services.
The FCC rules adopted in July 2026 were intended to close what the agency has called a “component part loophole” in its equipment-authorization regime. Under those rules, if a device would be prohibited from receiving a new FCC equipment authorization if produced by a Covered List entity, the device also is prohibited from authorization if it incorporates a logic-bearing hardware component produced by that entity. The rules therefore extend the Covered List restrictions beyond finished devices produced by listed entities to certain otherwise non-covered devices that incorporate covered components.
The FCC defined “logic-bearing hardware component” broadly to include a “device, system, module, sub-assembly, integrated circuit or other physical component” that uses digital techniques or radiofrequency energy to perform data-processing functions. As a practical matter, this means that manufacturers and other parties seeking equipment authorization need to assess not only the producer of the finished device but also the provenance of smart components incorporated into it.
The component-level rules are part of a broader expansion of the FCC’s Covered List framework. Over the past year, the FCC has also added categories of foreign-produced equipment, including uncrewed aircraft systems and critical components, consumer-grade routers, power inverters, and advanced robotic devices, to the Covered List based on national-security determinations by Executive Branch agencies. We discussed those developments in prior Inside Global Tech posts on UAS and UAS critical components, foreign-produced routers, and power inverters and advanced robotic devices.
The new logic-bearing-component prohibition is distinct from those place-of-production-based Covered List entries: the FCC’s July order applies the component restriction to producer/provider-based Covered List determinations, such as the listing applicable to Huawei, rather than to equipment categories listed solely because they are produced in a particular location. This first-of-its-kind enforcement action underscores the importance of component-level supply-chain diligence for manufacturers and importers of devices that require FCC authorization, particularly where products incorporate chips, processors, communications modules, or other smart components supplied by Covered List entities.