The
@FCC is writing communications-supply-chain rules that are very likely to shape how robots are built, tested, sold, serviced, and financed in the United States.
Today,
@RoboStrategy filed comments explaining why those effects deserve attention.
Some background: On July 22 the Commission adopted rules closing what it calls the “component part loophole” (basically in other words “we banned Huawei products but not Huawei parts . . . seems like something we ought to fix”), and they asked for the public’s feedback. Six days later, the Public Safety and Homeland Security Bureau added foreign-produced advanced robotic devices to the Covered List.
This leaves us with the FCC filing in communications supply chain rules that now reach robotics and physical AI. We have taken the opportunity to say a few things that we think they may not have fully accounted for.
From the get-go, I should state that the FCC’s objective is legitimate. The US has every right to and should protect communications equipment and networks from genuine national security threats. But robots are different from routers and handsets and rules focused on the latter shouldn’t unduly constrain innovation in the former. A connected robot may contain joint controllers, motor drivers, encoders, safety controllers, and power-management boards. Nearly all process digital information, yet many communicate only inside the machine and have no path to an external network. Treating every logic-bearing component alike could add substantial cost without addressing remote command, surveillance, or data-exfiltration risk.
We asked the FCC for rules that follow the actual architecture and economics of robotics. In short:
Use one clear, one-tier test for component origin.
Draw the component boundary at external reachability.
Preserve the distinction between named Covered List entities and restrictions based solely on production location.
Allow permanent software and firmware maintenance, along with safe hardware changes that do not alter radio frequency characteristics.
Keep a workable path for importing development units and operating customer pilots, which often last six to twelve months.
Match any bill-of-materials requirement to the origin test and protect competitively sensitive supplier information.
We also asked the Commission to protect existing authorizations and make enforcement predictable. Investors and manufacturers need to know whether regulatory action affects future sales, deployed machines, or both.
Security and American leadership in physical AI can advance together. Chairman
@BrendanCarrFCC identified onshoring investment as one measure of these actions. We agree. The proper path is a set of rules manufacturers can understand before they design products, qualify suppliers, and commit capital.