The binding constraint on U.S. robotics is now the bill of materials, not the model

The Federal Communications Commission added "advanced robotic devices" to its list of equipment banned on national security grounds last month, which means new models of foreign-made humanoids, quadrupeds, robot vacuums and lawn mowers cannot be sold into the American market ^[1][2]. To qualify for entry, a robot must be assembled in the U.S. with at least 65% of its components by value produced domestically, a share that rises to 75% in 2029 ^[3][4].

For anyone running a robotics roadmap, the gating item has moved. Capability demos and policy checkpoints are no longer the hard part; the hard part is a procurement document. The rule is not aimed at a single country on its face, but it is widely read as aimed at China, which dominates robotics manufacturing, according to Rest of World ^[5]. Incumbent products are grandfathered, and robots imported for development rather than sale are still permitted ^[6], so the burden lands hardest on companies whose first commercial model is still ahead of them.

That is the inversion worth noting. Anto Patrex, founder of San Francisco's CosmicBrain AI, which is building robots to fetch deliveries and carry laundry in apartment buildings, had his first products assembled in China and in early 2026 stood up an additional assembly line in Canada with key components still coming from China, an arrangement that does not qualify under the FCC rule ^[8][9]. "Look at Apple, it's made in China. How do you expect even more complicated products like robots to be built in America?" Patrex told Rest of World ^[7]. Apple assembles roughly 80% of iPhones in China and sources many components there ^[17]. Elizabeth Williams, founder of the New York company Gemma, which designs cosmetics robots that apply makeup, used a Chinese manufacturer for prototypes and told Rest of World it "would have been impossible to do that here" ^[10]. She asked how domestic manufacturing firms and founders would be incentivized ^[11].

Even the compliance-forward cases are not compliant. Michael Perry, head of commercial strategy at Houston-based Persona AI, said U.S. clients were asking for robots with no Chinese components before the ban existed, and that the company has been sourcing from Taiwan, Japan, South Korea and Italy ^[14][15]. Allied sourcing does not satisfy a domestic-value test, and Perry says Persona still has work to do to reach 65% ^[16]. His summary of the policy design: "You need to provide the carrot as well as the stick. Right now, you're only providing the stick" ^[16].

The supply-side reason this is hard is unglamorous. China's electric vehicle build-out expanded domestic production of sensors, batteries and actuators, the same parts robots need, and proximity to southern China lets Chinese robot makers iterate prototypes faster than foreign peers ^[18][19]. In the U.S., many robotics components are too expensive, too slow to procure, or simply unavailable ^[12]; Rest of World, citing The Information, reports that Silicon Valley employees have flown parts in from China in their suitcases ^[13].

Watch three things. Whether any domestic-content carrot appears alongside the stick ^[16]. Whether the development-use exemption holds, since it is currently the only legal route to fast prototyping ^[6]. And the 2029 step-up, which cuts allowable non-domestic value from 35% to 25%, a 29% reduction in imported content per unit ^[22].