Matic designs its floor-cleaning robot in Mountain View and assembles every unit in California. In an August interview, co-founder Mehul Nariyawala said the robot still falls short of the 65 percent domestic-content threshold behind the FCC's new rule on foreign-produced robots. On October 2 the company got an exemption: the Department of War granted a Conditional Approval for its floor cleaner and charging dock, and the FCC took those two models off its Covered List. The distance between assembling in California and passing that test sits in the bill of materials, and it's a number every robot team can compute today.
What the FCC counts
On July 28 the FCC added foreign-produced "advanced robotic devices" to the Covered List. A new model on that list can't receive the equipment authorization that any radio-emitting product needs before it's imported, marketed or sold in the U.S. As the law firm Wiley summarizes the notice, the rule covers mobile robots that weigh more than 4.4 pounds, counting the dock. To qualify, a robot must carry a sensor, a network link of at least 200 kbps, and software that controls navigation or data collection. Humanoids, quadrupeds, warehouse robots and robot vacuums all fit. FDA-regulated medical devices, surgical robots included, are excluded, as are fixed industrial arms and connected vehicles. Drones already sit on the Covered List under their own entry. A hospital delivery robot that FDA doesn't regulate as a device is in scope.
The FCC defined "foreign-produced" as anything that fails the federal Buy American test for a domestic end product. Under that test, a product must be manufactured in the United States, and its domestic components must cost more than 65 percent of total component cost for deliveries through 2028, or 75 percent from 2029. Final assembly in California settles the first condition. The parts inside the robot settle the second, and Matic's website says its components come from several countries.
What the exemption asks for
A company that fails the content test applies to the Department of War, which alone grants Conditional Approvals for robots. The application covers corporate structure, foreign ownership, supply chains, and a plan to build or grow U.S. manufacturing of the product. The approval lasts as long as the company keeps to that onshoring plan and passes continued vetting. If it falls behind, the models go back on the list. Matic was the third robotics company approved, after Husqvarna on September 9 and ANSCER Robotics on September 18.
Neither Matic nor the FCC's notice has disclosed the robot's current domestic share or the plan's milestones. A future Matic model, beyond the two named in the approval, would need its own approval or would have to pass the content test.
Robots already in the field
Models authorized before July 28 can keep shipping, but the FCC treats any change to covered equipment as requiring new authorization. A blanket waiver allows software and firmware updates, such as security patches, until at least January 1, 2029. Hardware revisions need a waiver of their own. When a supplier discontinues a camera module or a motor driver, the redesign that would otherwise be a change order now also needs a filing. Wiley notes the FCC has regularly granted such waivers for covered routers, but each one is still a filing on the redesign schedule.
Counting it in the BOM
A cost-rolled bill of materials carries a unit cost on every line. Add the country where each part is made, and the domestic share falls out of the same rollup. On a robot whose parts cost $400, the 65 percent test means more than $260 of them have to be U.S.-made. The expensive lines move that number most, and in a camera-guided floor cleaner like Matic's, with five cameras and an NVIDIA compute module, those are the cameras, the compute, the battery pack and the drive motors. Swapping one of them late means redesign, retest and, for an authorized model, a waiver filing.
Dave's take
The FCC borrowed a test written for government purchasing and pointed it at the robots sold into American homes, warehouses and factories, so a consumer product now answers to a contracting officer's arithmetic. Matic assembles in California and still needed the Department of War's sign-off, and a robot designed this year could launch its successor under the 75 percent bar.
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Dave Saunders is the founder of Base Reality Group and a Fractional CPO for product companies. He was a founder and operator at Galen Robotics, where the surgical-robotics platform earned FDA De Novo authorization in 2023, and he managed a 35-patent portfolio licensed from Johns Hopkins. He wrote Founders Who Finish and publishes The Build. More about Dave →