[Text by Hu Xiangxi, Edited by Lv Dong] Recently, the Federal Communications Commission (FCC) updated its Covered List to include foreign-produced advanced robotic equipment and networked inverters. This means that new models of Chinese robots will be largely unable to enter the US market. Previously authorized older models are not directly affected for now, but the FCC reserves the right to revoke existing sales authorizations.
The FCC's application system shows that several Chinese humanoid robot companies have previously completed registration with the FCC, including Unitree, Shenzhen Wuxin Technology, X Square Robot, Leju Robotics, and AgiBot.
Guancha.cn has synthesized information from multiple sources in an attempt to clarify the substantive impact and underlying logic of this ban on China's robotics industry.
Yang Jie, a senior partner at Huiye Law Firm, told Guancha.cn that from a legal operational perspective, the FCC's recent ban differs significantly from previous entity lists and export controls. The core difference lies in the fact that it no longer targets specific companies, but instead uses the place of production as the identification standard, imposing indiscriminate restrictions on all robots manufactured overseas, such as in China.
Another industry insider told Guancha.cn that the core of the ban lies in the determination of the place of origin; it regulates the final assembly process rather than the components themselves. This means that once the ban officially takes effect, Chinese robots assembled outside the United States will be deemed "Made in China" and restricted, similar to how Tesla's vehicles manufactured in China are classified as "Chinese-made NEVs (New Energy Vehicles)."
This has put a group of Silicon Valley companies conducting hardware R&D in China in a difficult position. They have to consider shipping components to Southeast Asia and other regions for assembly, but this also exposes them to new problems such as insufficient testing conditions locally.
Even so, companies still prefer to utilize the Chinese supply chain for assembly in third-party locations rather than reshoring to the US. The reason is simple: China possesses irreplaceable advantages in terms of cost, production capacity, and iteration speed.
Is the US Panicking? In the ban, the FCC's restriction scope on relevant robots is very broad. The core feature is the ability to "move," meaning they can perform movement, obstacle avoidance, navigation, or locomotion on land. Restricted equipment includes autonomous mobile robots, humanoid robots, and quadruped robots, which must be able to execute tasks at a distance from humans based on commands or sensor data; the combined weight of the equipment and its control station exceeds roughly 2 kilograms, equipped with sensors, supporting network or Bluetooth connections, and loaded with AI (Artificial Intelligence) software for control.
According to this standard, in addition to humanoid robots and robot dogs, warehouse handling robots, food delivery robots, and wheeled dual-arm robots may also fall into the restricted category.
The FCC explicitly stated that unmanned underwater robots, medical surgical robots, prosthetics, walking aids, and industrial robotic arms are not subject to the restrictions.
At a time when the robotics industry has not yet truly ushered in explosive growth, and Chinese companies' products are only testing the US market on a small scale, the US government is eager to roll out the ban, which reflects a sense of insecurity behind the scenes.
Industry insiders point out that currently, there is actually a group of Silicon Valley embodied AI companies doing hardware in China. After the ban is introduced, they may have to transfer components to Southeast Asia for assembly. However, Southeast Asia still has shortcomings in processes and craftsmanship in the testing phase, which cannot be solved by a simple relocation.
The US's approach seems like "taking precautions," but in reality, it reflects a mentality of lacking confidence, rushing to build walls before industrial competition has truly begun.
In fact, the maturity of Chinese robot products is already quite high, to the extent that the booming embodied AI industry in the US cannot ignore their value.
Many embodied AI R&D companies in the US, when selecting hardware, especially when looking for stable, high-performance, and reasonably priced robot bodies, have found that there are almost no alternative products to Chinese brands locally in the US.
For example, data from Counterpoint Research shows that Unitree Technology accounts for nearly one-fifth of the global humanoid robot market share. Products like the G1, which have already been registered with the FCC, have high maturity, and the market demand for new models is not urgent.
However, technologies such as dexterous hands and dexterous gripper operating arms are not yet mature and still require the iteration of new models. This is precisely the key link that the ban might choke off.
At present, the impact of this ban on China is relatively limited. The reason is that domestic robot companies have not yet reached the node of going global in the industry, and are basically not prepared for overseas expansion. The overall global robotics market has not yet formed a scale, and shipment volumes remain at a low level. Therefore, the impact of the ban is more reflected in psychological and planning aspects rather than substantive shocks.
Yang Jie told Guancha.cn that from a legal operational perspective, this FCC ban is obviously different from past entity lists and export controls. It identifies regulated objects based on the place of production rather than the corporate entity, without distinguishing the nationality of the enterprise; as long as it is manufactured overseas, it is restricted. This method of determination appears neutral on the surface but is actually highly targeted.
Under the global supply-chain landscape, China occupies a dominant position in the field of robotics, which in essence constitutes discrimination.
The FCC announcement also explicitly reserves the right to revoke existing product sales authorizations, based on the simplified procedures for revoking authorizations in FCC rules. This means that even authorized products may face post-facto bans.
Yang Jie stated that the main basis for the FCC to revoke licenses is mostly classified assessment reports from intelligence agencies. The US government usually invokes national security privileges to refuse full disclosure of evidence, making it difficult for companies to obtain the basis of the accusations and conduct effective rebuttals. Long-term precedents in US federal courts show that for administrative determinations involving national security and supply-chain controls, courts only review procedural flaws and do not substantively review whether the risk conclusions are objectively true. As long as the FCC completes the written notification process, courts usually uphold the revocation decision.
This ban is not without exception channels. The FCC has explicitly established a conditional approval exemption mechanism. Foreign robot manufacturers can apply to the US Department of Defense. If the competent authority determines that a certain device does not pose unacceptable risks, the FCC will update the list accordingly to allow the device to be authorized. The FCC has set up a dedicated email address to receive applications.
Yang Jie analyzed that the establishment of this exemption mechanism involves multiple considerations. First, as a communications regulatory agency, the FCC does not have the professional capability for national security reviews and must rely on the technical judgment of executive branches. Granting the exemption power to the Department of Defense is an inevitable result of the division of functions. Second, the US photovoltaic and robotics industries are highly dependent on foreign supply. Completely cutting off the supply will impact its own industries, and conditional approval buys a transition period for supply-chain adjustments. In addition, vague standards give the executive department flexibility in case-by-case discretion, which can be used as a bargaining chip in diplomatic negotiations.
However, applying for an exemption is not an easy task.
In the past, some Chinese companies have tried to transfer the entire industrial supply chain to the US, but the cost is too high, and successful cases are rare. Applying for conditional exemptions often requires endorsement from large US companies, and is limited to specific uses and products, making a full lifting of the ban impossible.
The focus of exemption approval lies in verifying whether the robot's core sensors, computing power chips, and control algorithms are decoupled from the Chinese supply chain, while also considering the degree of rigid demand for the product in US manufacturing and critical infrastructure. The review threshold for rigid demand categories is relatively lenient.
China's Trump Card Although the US sets obstacles at the whole machine level, which can restrict Chinese robot whole machines from entering its market, it is impossible to reject the deep participation of the Chinese supply chain.
Data shows that Chinese suppliers account for about 70% of the core components of Tesla's Optimus humanoid robot. The "The Humanoid 100" report released by Morgan Stanley in February 2025 also pointed out that among the top 100 companies in the global humanoid robot industry chain, Chinese companies account for 56%, and China's share in the global humanoid robot industry chain is as high as 63%, dominating the global supply chain.
Specifically for Tesla's Optimus, its outsourced components account for 61% of the total cost, and Chinese suppliers occupy an absolutely dominant position in core hardware links such as actuators, reducers, ball screws, and motors. If Chinese components are removed, the unit cost of Optimus will soar from $46,000 to $131,000, far exceeding its target price of $20,000.
This cost advantage enables the Chinese supply chain to not only dominate production and share in the global robotics industry but also grasp key pricing power and profit distribution rights in the value chain. By the end of 2025, the localization rate of core components for domestic humanoid robots has increased to 75%. By 2026, the localization rate of the three major core components—reducers, servo systems, and controllers—will further rise to 75% to 90%.
Various data indicate that even if the US chokes off the final assembly link, it cannot bypass China's core position in the field of components.
In the production of robots, key components including reducers, servo motors, controllers, and various sensors constitute the "bones," "muscles," and "nerves" of the robot's body.
The ban regulates final assembly rather than components, so key components such as reducers, servo motors, and sensors still need to be supplied from China. These components are the core parts of robots, and it is difficult for the US to find alternative sources in the short term.
China not only has a complete localized supply chain in the field of core components such as motors, reducers, and sensors, but also holds absolute speaking power in underlying raw materials.
The importance of rare earth resources cannot be ignored. Rare earths are the underlying materials of the supply chain. Rare earth permanent magnet materials are key materials for servo motors and joint motors. Neodymium-iron-boron (NdFeB) magnetic materials have excellent magnetic properties and high torque density, which can output strong torque while keeping the motor small in size and light in weight, providing stable power for humanoid robots to perform complex movements such as walking, grasping, and stretching.
During the US tariff turmoil last year, Tesla CEO Elon Musk stated that due to China's export controls on rare earths, the production of the company's humanoid robot Optimus was affected, and Tesla is working with the Chinese side to strive for export licenses.
This fully demonstrates that China’s leverage over rare earth supplies can directly affect global robot production schedules.
The advantages of the Chinese supply chain lie not only in cost but also in production capacity and iteration speed. China is a combination of these three elements—cost, capacity, and iteration speed—which is unique globally.
Precisely because of understanding the high value of the Chinese supply chain, more people in the industry are actually considering how to circumvent the US ban rather than decoupling from the Chinese supply chain. The US ban will not lead to the reshoring of the supply chain to the US, but will instead spawn various circumvention solutions.
In the future, such a pattern may emerge: China firmly controls the production of core components such as reducers, servo motors, and sensors, and undertakes the most technology-intensive R&D and product iteration; while the assembly link may be migrated to third-party countries such as Southeast Asia and Mexico.
Guancha.cn has learned from the industry that currently, some Silicon Valley companies that had planned to assemble in China are beginning to consider choosing to use the Chinese supply chain to assemble elsewhere. This not only bypasses the restrictions on the place of origin but also retains the cost and efficiency advantages of the Chinese supply chain.
From a global perspective, Chinese robot manufacturers are also actively expanding into diversified markets. In 2025, China's industrial robot export volume reached $8.03 billion, accounting for 11% of the global share, surpassing Germany for the first time to become the world's second-largest industrial robot exporter. ASEAN countries have become an important destination for China's industrial robot exports. In 2025, 35% of China’s industrial robot exports went to ASEAN, a higher share than in 2024. These countries are becoming important destinations for China's manufacturing going global, and at the same time, they are becoming potential markets for robot products.
The current situation faced by China's robotics industry has similarities to the US restricting China's computing power development in the past. When China developed domestic chips and domestic large models, it also faced difficulties in obtaining computing power, but ultimately found solutions through technological breakthroughs and market-oriented paths. The same applies to the robotics field; supply-chain advantages are China’s strongest trump card in this contest. The US restriction on Chinese robot whole machines may instead prompt China to accelerate its catch-up in robot technology iteration and application implementation, while US local companies, unable to obtain high cost-performance products from the Chinese supply chain, may fall behind in product development and cost control.
Yang Jie suggested that in the face of such list sanctions, Chinese companies can actively utilize the conditional approval channel in the short term, submit applications to the US Department of Defense, and prepare materials such as complete supply-chain disclosure, bills of materials, and equity structures; models already authorized by the FCC need to ensure that certification statements are true and accurate to avoid triggering revocation clauses; and evaluate the feasibility of setting up production capacity in the US or third countries to strive for domestic end-product recognition.
From a medium to long-term perspective, compliance capability has become a core competitiveness. It is necessary to build a diversified and regionalized global supply-chain layout, strengthen independent R&D of core technologies in key fields, actively participate in the formulation of international standards, be familiar with US administrative law procedures, and protect rights through legal channels at appropriate times. Overseas destinations should also be diversified. In addition to the US market, companies should actively explore markets in the EU, Southeast Asia, the Middle East, Latin America, and other regions to reduce dependence on a single market.
The US restriction on Chinese robots is essentially to protect its own industries, but the global division of labor pattern of the supply chain has already formed, and China's leading position in the field of robot hardware is difficult to shake in the short term.
The US can block Chinese robot whole machines from entering the market, but it cannot reject the integration of Chinese-made components and materials into the global robot industry chain.