What Congress is left with now that the FCC acted. The FCC added foreign-produced humanoid and quadruped robots to its Covered List this week, effective July 28. Most of the commentary focuses rightfully on what the designation does to the robots but its also interesting to consider what it does to the robotics bills proposed in Congress, given that there are overlaps on policy. First (and obvious) observation: if you like a policy, you always want it codified into federal statute, not just have it reflected in agency action. The current admin can always changes its mind, or the next guy could have a different policy altogether and rescind what the agency did. Statutes are far harder to repeal or amend. If you like the natsec finding and the FCC action, then you want to see it and things like it get enacted through Congress. Okay with that out of the way, let's start with the GUARD Act. Its central mechanism was to direct the national security agencies to review adversary-produced humanoids and quadrupeds and to place the ones presenting unacceptable risk on the Covered List, with automatic addition for anything not reviewed within a year. Big overlap with the FCC's actoin but the bill sets out procedure. It would supply a review standard, a timeline, and a default rule for a designation authority the agency has already shown it will exercise without any of those things. It also catalogues what can't hit the Covered List. Like the FCC action, it operates prospectively through equipment authorization, which means it constrains new models seeking clearance to enter the U.S. market. Hardware already authorized and already deployed sits outside it. It also operates at the level of the finished device, which leaves the component question unaddressed. A different bill addresses capital flowing to robotics. The Cassidy and Coons bill from last November would amend the Defense Production Act to treat any investment by a covered-nation entity in a U.S. business that designs, tests, develops, or manufactures humanoid robots as a covered transaction, expressly without regard to whether the investment results in control, and with a mandatory declaration attached. An interesting potential attachment to the FY2027 NDAA. We now have at least four different descriptions of the thing being regulated. The FCC has made a designation. The NDAA provision covers military procurement of certain humanoids. Cassidy and Coons proposed a four-part conjunctive test requiring, among other things, that the machine understand natural language commands. GUARD abandoned that approach in favor of counting articulated limbs. These do not describe the same population of machines, and the divergence would undoubtedly raise a number of difficult compliance questoins if all of these definitions became effective. Wheeled mobile manipulators with two arms fall inside some of these definitions and outside others. When agency action front-runs the statute, the statute often arrives to ratify what the agency did and to fill the gaps the agency could not reach, and definitional inconsistencies get cleaned up over the course of years, sometimes following the lead of the market which had to operate based on educated guesses.

👀👀👀 National Security Determination on the Threat Posed by Foreign-Produced Advanced Robotic Devices July 27, 2026 "The Trump Administration’s AI Action Plan identifies robotics as a next-generation technology essential to our defense and national security. Robotics technology is rapidly advancing, driven by enhancements in AI, sensing, and actuation technologies. Advanced robotic devices will be critical to creating efficiencies in our economy, dominating on the battlefield, and securing our homeland. To ensure the United States is able to take advantage of this generational technology, the United States must have an independent and resilient robotics supply chain and industrial base. As the 2025 National Security Strategy states, “The United States will reindustrialize its economy, ‘re-shore’ industrial production, and encourage and attract investment in our economy and our workforce, with a focus on the critical and emerging technology sectors that will define the future.” As the technology matures, advanced robotic devices have growing use cases in monitoring and securing critical infrastructure. Robots are often equipped with high-fidelity sensors, including Light Detection and Ranging (LiDAR), tactile, acoustic, and thermal sensors that collect and maintain sensitive data on their surroundings. Advanced robotic devices are inherently networked systems which creates broad attack surfaces and leaves them vulnerable to data exfiltration, remote disruption of the physical robot, and dependencies on unsecure over the air updates. The data collected by advanced robotic devices, especially those securing sensitive locations and critical infrastructure must be protected and maintained in the United States. In addition to securing critical infrastructure, advanced robotic devices also have applications in industrial manufacturing, from material handling to order fulfilment. Integrating these technologies into American manufacturing will lower production costs, increase output, and support America’s reindustrialization. In order for the American economy to rely on these technologies, we must have a secure domestic advanced robotics supply chain and industrial base."

FCC Adds Foreign-Produced Power Inverters and Robots to Covered List Public notice and fact sheet available at the link above. In brief: The FCC's Public Safety and Homeland Security Bureau added two new categories to the Covered List: foreign-produced power inverters and foreign-produced "advanced robotic devices" (defined as mobile robots, including humanoids and quadrupeds). This follows two National Security Determinations transmitted to the FCC on July 27 by a White House-convened Executive Branch interagency body. The FCC has no independent authority to make the underlying national security finding. Under the Secure and Trusted Communications Networks Act, the Commission is obligated to add equipment to the Covered List once it receives a qualifying determination from the Executive Branch interagency body; the Public Notice is explicit that PSHSB's role here is non-discretionary. The operative restriction is that covered equipment cannot receive FCC equipment authorization, and since most electronic devices need that authorization before import, marketing, or sale in the U.S., this functions as a de facto import/market-entry ban for new models going forward. Like the UAS (Dec. 2025) and router (Mar. 2026) additions, this covers anything "produced in a foreign country," regardless of the producer's nationality — the same categorical approach rather than a company-specific blacklist (Huawei, ZTE, etc.). Previously authorized models can still be sold, imported, and used; existing owners are unaffected; and federal government purchase/use is entirely carved out. DHS or DoW can grant approval to a specific inverter or inverter class; DoW alone handles robotic device approvals. Applications go through a guidance-document process to conditional-approvals@fcc.gov, mirroring the UAS/router precedent. Both determinations lean on supply chain vulnerability and cybersecurity risk — remote connectivity enabling data exfiltration, remote shutdown, or "commandeering" by foreign actors. This is the first time the Covered List framework has been extended to humanoid/quadruped robots by direct executive action, ahead of the GUARD Act that would codify a similar process legislatively. This shows how the administration is willing to move on robotics-specific national security restrictions without waiting on Congress, and it will likely shape how the GUARD Act debate proceeds.

The @FCC 's Title III equipment certification power under the Communications Act gives them authority over devices that emit or use radio frequency—WiFi, cellular, proprietary wireless comms, spectrum-based sensors. If a humanoid robot contains any wireless capability, it falls under FCC jurisdiction as RF equipment. The FCC can refuse to certify non-compliant equipment, which effectively bans it from importation and domestic sale. The FCC has deployed this authority increasingly for national security purposes. The Huawei ban and more recent actions restricting Chinese telecom equipment used this framework: the FCC denied equipment certifications based on national security findings, invoking Section 309(j) of the Communications Act and emergency authority. They could theoretically do the same for Chinese robots with RF components—certifications denied on the grounds that the equipment poses risks of espionage, surveillance, or critical infrastructure vulnerability. If this news is true, it will be interesting to see whether the FCC follows this playbook.

People ask if America is losing the robot arms race against China. Arms are the workhorse of automation. They do 90% of automotive welds and stack pallets by the billion. 621,000 were installed last year alone. So... does the US have a leading supplier?

Some thoughts on this important report on @standardbots published by @RoboStrategy . The big ticket item is the industrial policy question that SB calls: more state-sponsored financial support for manufacturers. Standard Bots has been advising the @WhiteHouse and Congress on a National Robotics Strategy, including testimony to the Joint Economic Committee and the Subcommittee on Research and Technology, and the recommendations include direct financial support for American manufacturers investing in robotics. It’s akin to the CHIPS Act model applied to robotics adoption rather than robotics manufacturing on its own. The open question is whether the intended beneficiary of such support should be domestic robot producers, the manufacturers who buy and deploy robots, or both. Second, SB recommends a ban on Chinese-made industrial robots and robotics components, which is obviously a bigger step than just instituting a tariff. But such a move would raise the familiar tension between supply chain security, on one hand, and cost or availability of inputs for domestic manufacturers, particularly small and midsize ones without alternative domestic suppliers at comparable price points. This parallels the semiconductor and EV battery decoupling debates, where the same tradeoff between resilience and near-term competitiveness was front and center. Moreover, any serious ban on Chinese robots eventually runs into the question of what is actually being restricted: the hardware, the compute stack underneath it, or both? And that is a harder line to draw than it is for pure semiconductors given how much of the value in AI-native robotics sits in software and training data rather than the physical unit. A third point is competitiveness benchmarking. US robot density stood at 295 units per 10,000 employees in 2023, well behind the world's leaders, according to the International Federation of Robotics. Data like this helps to anchor legislative and rulemaking. It matters which countries are seen as "world leaders" relative to the US, since the policy prescription differs depending on whether the benchmark is South Korea and Singapore or Germany and Japan, or whether the metrics show China in the lead. A fourth point is the labor market framing. Manufacturing (if you affiliated suppliers and services) still accounts for roughly a third of the US economy and a third of American jobs. Robotics advocates generally frame automation as backfilling labor shortages rather than displacing workers, which isn’t wrong! That framing helps reach the right policy prescriptions, and ones that are more likely to enjoy bipartisan support. One must concede, however, that more empirical analysis is, particularly at the small and midsize end of the market where adoption is newest. Fifth and final point pertains to safety and the implications "no-code" deployment. The “show, don't code” approach lowers the programming barrier. It does not lower the physical one, since fixturing, safety, end-of-arm tooling, and floor space remain real engineering projects. That distinction matters for @OSHA_DOL and ANSI and RIA robot safety standards, which were largely written assuming specialized integrators handle deployment. If demonstration-based programming genuinely puts arm deployment within reach of manufacturers without in-house robotics expertise, safety certification and liability regimes may need to update faster than the underlying statutes anticipate. This will be an interesting issue to watch going forward. Read the Standard Bots report for more 👇

On Friday, @Robostrategy filed a comment letter with the @SECGov on its proposed Registered Offering Reform (File No. S7-2026-17). We write as proponents of, and investors in, American humanoid robotics and physical AI. These industries are capital-intensive, their development cycles run long, and much of the value is created while the companies are still private. Our view is that access to public-market capital on competitive terms and from domestic sources, is one of the more consequential inputs to American innovation in the space. Where American robotics companies cannot raise that capital here, they tend to raise it abroad, and technological leadership has a way of following the funding. They also find it much harder to compete on the global stage. The SEC’s proposed reform would help address the frictions with raising capital through the public markets for young, innovative companies. It would remove the public-float and one-year seasoning gates that keep newer and smaller issuers off the streamlined shelf, and extend to listed closed-end funds the same on-demand access that seasoned operating companies already have. Chairman @PaulAtkins has described the current rules as "unnecessarily constraining" the ability of public companies to raise capital quickly, and has framed the package as part of a broader effort to encourage more companies to become and remain public. We share that reading and applaud his leadership on this issue and that of the Administration writ large. Our letter does two things. First, it endorses the proposal, and situates it within a wider, bipartisan modernization effort that runs from the @FAANews's drone framework to @NHTSAgov 's autonomous-vehicle rules to the @US_FDA 's approach to AI-enabled devices, each retiring a rule built for an earlier era while keeping the underlying protection intact. Capital formation deserves the same treatment. Second, it asks the Commission to finish the work. An automatically effective shelf does little for a closed-end fund that, under the Investment Company Act, cannot practically sell into it. Section 23(b) conditions below-NAV sales on a shareholder vote that no fund can realistically refresh for day-to-day issuance. We ask the Commission to use the exemptive authority it already holds to provide a workable, investor-protective path, with clear dilution disclosure, board oversight, and quantitative limits. We make sure to call out the elephant in the proverbial room, that being China ensuring that their robotics and AI industries have streamline access to large capital markets. Chinese technology companies have raised about $3.1 billion through mainland IPOs through mid-2026, more than five times the prior-year volume, and nearly fifty issuers were queued on the STAR Market and in Shenzhen seeking a combined 126.1 billion yuan, on the order of $18 billion. Because listing eligibility runs through state approval of a company's core technology, Beijing can steer that public capital toward its strategic priorities with a precision private venture funding does not offer. What China is doing on the capital markets front as it relates to robotics is an important reference point. We recognize the competition and its implications, but we do not view this as a contest the United States must win at another country's expense. Innovation is global, and the contributions that will build this technology will come from many places. Even so, the capital this proposal could help unlock is the kind on which American leadership in physical AI, and the national-security interests bound up with it, may ultimately depend. The full letter will be posted when the agency makes all comments available to the public.

Interesting analysis of the legal landscape in the EU applying to "the convergence of AI and industrial machinery". "Europe’s industrial strategy depends on deploying AI-enabled robotics at scale. Workforce gaps are widening, manufacturing competitiveness is under pressure, and automation remains the most credible answer — yet manual work still dominates high-value discrete manufacturing despite centuries of incremental progress. Regulatory uncertainty risks becoming the very thing that slows adoption at precisely the moment Europe can least afford it."

I've just finished writing a 6,000 word Investment Memo on @standardbots It will be published at @RoboStrategy soon, covering: - The birth of the robot arm - A typical robot arm’s hardware and software architecture - How Standard Bots is reinventing the arm from first principles

The opportunity for passing CLARITY cannot be overstated. The United States must be THE leader in crypto and any financial and technological innovation - and if you don’t make the rules you don’t lead (or even have a seat at the table). Pass CLARITY!