The Federal Communications Commission (FCC) officially updated its “Covered List” to ban new foreign-produced connected power inverters from receiving FCC equipment authorizations.  Directed by a White House-convened interagency body, this regulatory change targets supply chain vulnerabilities and the risk of cyberattacks on U.S. critical infrastructure, introducing major compliance requirements for the renewable energy and technology sectors. 

Impact on New Authorizations

Equipment placed on the FCC’s Covered List is prohibited from receiving FCC equipment authorization.  Because this authorization is a strict prerequisite prior to import, marketing, or sale, new models of foreign-produced power inverters are now effectively blocked from entering the U.S. market. 

Scope of Affected Equipment

The FCC and national security determinations have established specific parameters for the affected hardware. To face restriction, the equipment must meet both of the following criteria:

• Functionality: It is a bi-directional power device (including microinverters, string, central, and battery-based hybrid inverters) that converts direct current (DC) electricity to alternating current (AC), or vice versa.
• Connectivity: It contains components that enable remote communication, control, data collection, or monitoring (e.g., via Wi-Fi, cellular, or Bluetooth).

The “Buy American” Test

To define what constitutes “foreign-produced,” the FCC leverages the standard for a “domestic end product” under the federal Buy American regulations (48 CFR § 25.101(a)). Governed by the Buy American statute and Executive Orders 13881 and 14005, this framework establishes a strict two-part test. To qualify as a “domestic end product,” an article must meet both of the following criteria:

1. U.S. Manufacturing: The article itself must be manufactured within the United States.

2. Component Cost Thresholds: For standard manufactured end products, the cost of domestic components must exceed 65% of the total component cost for items delivered between 2024 and 2028 (rising to 75% in 2029). Note that this domestic content test is generally waived for acquisitions of Commercially Available Off-The-Shelf (COTS) items, or commercial products sold in substantial quantities in the commercial marketplace and offered to the government without modification.

Exemptions and Existing Use

The FCC ruling is explicitly forward-looking, applying only to new equipment authorizations.  It includes a few notable exemptions: 

• Grandfathered Technology: Retailers can continue to sell, and consumers and developers can continue to use, existing inverter models that previously received FCC authorization.
• Federal Purchases: The action does not restrict purchases made exclusively by, or for the use of, the U.S. federal government or federal agencies. 

Pathways for Conditional Approval

To provide a pathway for compliance, the Executive Branch has established a formal evaluation process allowing foreign-based producers to submit requests directly to the Department of Homeland Security or the Department of War.  If a manufacturer can demonstrate that their inverters pose no unacceptable national security risk, they may be granted “Conditional Approval,” thereby exempting those models from the Covered List restrictions.