White House Issues Proclamation on Robotics

The White House has formally declared robotics and industrial machinery imports a national security concern. Here is what changed, what did not, and what robotics companies should be doing now.

The October 28 Proclamation

On October 28, 2026, the President signed Proclamation 11077, “Adjusting Imports of Robotics, Industrial Machinery, and Their Parts and Components into the United States,” under Section 232 of the Trade Expansion Act of 1962. In the Proclamation, the President concurred with the Secretary of Commerce’s findings that robotics, industrial machinery, and their parts and components are being imported in quantities and under circumstances that threaten to impair US national security. Such a finding opens the door to action under Section 232.^[1]

The Proclamation directs the Secretary of Commerce and the US Trade Representative (USTR) to negotiate agreements with trading partners to address the national security threat.

The Secretary of Commerce and the USTR must update the President on the negotiations within 180 days, which is on or about April 26, 2027. Depending on the outcome of the negotiations, the President may impose or modify tariffs, duties, quotas, or fees. He may also consider additional remedies, including establishment of a program to incentivize new investment in US production of robotics and industrial machinery, as well as their parts and components. The Secretary of Commerce will continue to monitor these imports and will advise the President if further Section 232 action may be needed. 

The bottom line for today is there are no changes yet. There are no new tariffs, quotas, or fees; no tariff codes have been identified; and current duty rates still apply.

This attention toward robotics follows action by the Federal Communications Commission (FCC). On July 28, 2026, the FCC added “foreign-produced advanced robotic devices” (defined as mobile robots, such as humanoids and quadrupeds) to its Covered List.^[2] Devices on that list cannot receive FCC equipment authorization. Without that authorization, new models (and in some cases modified models) cannot be imported, marketed, or sold in the United States. What matters is where a robot is made, not who makes it.

Models authorized by the FCC before July 28, 2026 can stay on the market, and an FCC waiver keeps certain software and firmware updates flowing until at least January 1, 2029.^[3] Companies can also apply to the Department of War (DoW) for a Conditional Approval, and DoW has been granting them in batches since September.^[4] In considering a request for Conditional Approval, the DoW looks closely at national security risk, supply chain resilience, and a company’s commitment to building manufacturing capacity in the United States.

Why Robotics Companies Should Pay Attention

• Two separate regimes. The FCC action already restricts market access for new foreign-produced mobile robots. The Proclamation now opens a second front: possible trade remedies on a much broader set of products. Those products include industrial machinery and its parts and components, not just finished robots. Clients should assess their exposure under each regime separately.
• Supply chain and cost exposure. According to the Secretary of Commerce’s findings, the United States relies on imports for most types of robotics, industrial machinery, and their components, and domestic production falls short of national security needs. Tariffs or quotas adopted later could raise the cost of imported equipment, components, and replacement parts. That risk is greatest for long-lead capital projects and multiyear supply commitments.
• Cybersecurity focus. The Secretary of Commerce specifically found that robotics and machinery from certain foreign entities pose security risks because these systems routinely process and store sensitive data. Expect continued scrutiny of connected systems, firmware, and data flows.
• Opportunity for domestic producers. The Proclamation contemplates an investment incentive program for US production as a remedy under consideration by the President. The FCC Conditional Approval process likewise rewards commitments to US manufacturing capacity. Clients that manufacture, or plan to manufacture, in the United States may benefit from both.

Recommended Next Steps for Robotics Companies

1. Know your exposure. Map imported robotics, machinery, and components by product, country of origin, and current HTS classification so that any future remedy can be assessed quickly.
2. Check your contracts. Review supply, purchase, and distribution agreements for tariff allocation, price adjustment, change-in-law, and force majeure provisions, and consider addressing Section 232 risk in pending negotiations.
3. Confirm your FCC status. For mobile robot products, confirm FCC authorization status and evaluate whether a DoW Conditional Approval application is required for new or modified models.
4. Revisit your US footprint. Evaluate US manufacturing or onshoring plans in light of the possible investment incentive program or desire to seek a Conditional Approval.

ENDNOTES

[1] Section 232 of the Trade Expansion Act authorizes the President to adjust imports of items that threaten national security. The process begins with an investigation by the Secretary of Commerce into how imports of the article affect national security. The Secretary then sends their findings to the President who decides what action to take. One option is to negotiate an agreement that limits or restricts imports of the article into, or exports of it to, the United States. If no agreement is reached within 180 days of the President’s determination, or an agreement is not being carried out or does not eliminate the threat, the President “shall take such other actions as the President deems necessary to adjust the imports of such article so that such imports will not threaten to impair the national security.” https://www.law.cornell.edu/uscode/text/19/1862

[2] https://docs.fcc.gov/public/attachments/DOC-423682A1.pdf

[3] https://docs.fcc.gov/public/attachments/DA-26-789A1.pdf

[4] DoW reviews each application individually for “unacceptable risks.” The review assesses national security risk, supply chain resilience, and whether the applicant is committed to building trusted manufacturing capacity in the United States. Applicants must submit documentation regarding plans to onshore manufacturing to the US, corporate structure, and supply chain disclosures. https://www.fcc.gov/sites/default/files/robots-ca.pdf.

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