Can US companies legally deploy Chinese robots? (Living tracker)

The short answer

Direct answer: No federal measure in force today prohibits a private US company from buying or deploying a Chinese-made robot. Every binding restriction targets federal procurement — agencies, contractors, and federally funded purchases. But the boundary moved quickly in 2026; one pending bill, the GUARD Act, would reach the private market by blocking imports of new units; and the exposure is asymmetric: a fleet that is legal to run today can face limits on redeployment or resale value if its maker — or one component supplier — is added to a restricted list.

188Companies on the Pentagon's Section 1260H 'Chinese military companies' list after the June 8, 2026 update, which added Unitree and RoboSense (lidar supplier Hesai has been listed since January 2024)Source: DoD Section 1260H list, June 8, 2026

What is actually restricted right now?

The reasoning behind the December drone action — from the National Security Determination the FCC acted on — is the same logic now being applied to ground robots:

"UAS are inherently dual-use: they are both commercial platforms and potentially military or paramilitary sensors and weapons."

— National Security Determination of Dec 21, 2025, as quoted in FCC Public Notice DA 25-1086

What is proposed but not law?

"If the appropriate national security agency does not make a determination as required by paragraph (1) within 1 year after the enactment of this Act, the Commission shall add all covered robotics communications equipment or services to the covered list."

— GUARD Act, H.R. 9129, Section 2(a)(3)

Three federal signals — plus the state level — frame where this goes next:

• The House Select Committee on the CCP is re-running its DJI sequence on Unitree: a public letter naming the company (May 2025), a follow-up letter asking the Pentagon to list it (December 2025), the 1260H listing six months later (June 8, 2026), and now Covered List legislation (the GUARD Act) — which a US humanoid maker, Agility Robotics, has publicly endorsed.
• The Connected Vehicle Security Act (S. 4429) — which would write the Commerce connected-vehicle ban into statute — advanced through the Senate Commerce Committee on July 22, 2026. Whether its definition reaches off-road autonomous machines is unresolved, and worth watching.
• FY2025 NDAA Section 1078 is easy to miss: it required a DoD study of adversary-made ground robots, with a procurement ban that activates one year after the report if the report recommends it. Whether that report was ever delivered has not been publicly confirmed.
• At the state level, no state restricts Chinese ground robots today — but a growing list of states (Florida, Tennessee, and Connecticut among them) restrict Chinese drones for public agencies, the pattern state robot bills would most likely copy.

Why is "legal today" not the end of the analysis?

Two precedents show what happens after equipment is added to a restricted list — and they end differently:

• Huawei/ZTE network gear (the hard case): Congress appropriated $1.895 billion in 2020 to remove already-deployed covered telecom equipment — the removal program known as "rip and replace"; carrier demand reached ~$4.98 billion (Congress eventually funded the gap in December 2024), and as of June 2026 only 53 of 126 funded projects (42%) had finished the removal. Equipment that was legal when installed later had to be removed at public expense.
• DJI drones (the split case): the federal Covered List action was prospective — deployed fleets were grandfathered (already-purchased units may continue operating), and used DJI prices have so far held or risen, not collapsed, as restricted supply tightened. But an October 2025 FCC order created a procedure to restrict previously authorized covered equipment — barring its continued marketing and importation, while expressly not revoking the underlying authorizations — and the FCC used it for the first time on June 26, 2026, against equipment added to the Covered List in 2024 or earlier (deployed units can still be used; new supply is cut off). Florida's 2023 state ban went further and grounded agency fleets outright — an industry-estimated ~$200 million of aircraft against a $25 million state replacement fund.

$1.9B → ~$4.98BAppropriated vs. eventual demand to remove deployed Huawei/ZTE equipment under the FCC's rip-and-replace program — a ~2.6× overrun on stranded-asset costSource: FCC / Congress; carrier demand per FCC Chair letter, 2024

No part of the market has put a price on this risk yet. Rovara found no documented case of a US buyer canceling or reducing Chinese-robot purchases for regulatory reasons, and no robot-specific insurance exclusion (though general AI exclusions are spreading in US liability policies, and those can reach an AI-driven robot without naming it). Chinese humanoids meanwhile list far below Western units — a Unitree G1 is priced at $13,500–16,000 against six-figure Western humanoids, roughly a tenth of the price. Buyers should treat part of that discount as compensation for a regulatory risk that no underwriter, lessor, or resale market currently quantifies.

What should a buyer check before deploying?

1. Component provenance, not just the brand. Section 889 works at the component level: a covered camera or radio module inside an otherwise unlisted robot is the exposure. Note that warehouse-robot maker Hikrobot is a Hikvision subsidiary — the closest existing tie between an AMR vendor and a named 889 entity (and the FCC's Covered List reads its entries to include subsidiaries and affiliates, for the equipment categories each entry covers). Lidar matters too: RoboSense and Hesai, which supply many robot OEMs, are both 1260H-listed.
2. Your federal-contract surface. Section 889 Part B binds a contractor enterprise-wide — a Chinese robot in a private warehouse can matter if any part of the business holds federal contracts.
3. Security posture. Independent researchers Andreas Makris and Kevin Finisterre published a CVE-assigned vulnerability (CVE-2025-35027) allowing root takeover of Unitree Go2/B2/G1/H1 units via Bluetooth; robot-security firm Alias Robotics separately reported undisclosed telemetry to servers in China, and a pre-installed remote-access tunnel ("CloudSail") was flagged in a 2025 congressional letter. The telemetry claim is researcher-attributed, not government-confirmed. Unitree acknowledged the vulnerabilities in September 2025 and said it had fixed most of them; subsequent reporting through mid-2026 said a full fix had not yet shipped.
4. Exit value. Ask who buys the unit if the rules change. The GUARD Act's auto-listing mechanism means deployability can change without any new vote.

FAQ

Are Chinese robots banned in the US? No. As of July 24, 2026, no federal measure prohibits a private company from buying or operating a Chinese-made robot. Every restriction now in force targets federal procurement — agencies, contractors, and federally funded purchases — not private commercial use. Pending bills would tighten these restrictions; one, the GUARD Act, would reach the private market by blocking imports of new units.

What did the Pentagon's Unitree designation actually do? On June 8, 2026, the Pentagon added Unitree (Hangzhou Yushu Technology) and lidar maker RoboSense to its Section 1260H list of 'Chinese military companies' (lidar maker Hesai has been listed since January 2024). Under Section 805 of the FY2024 NDAA (P.L. 118-31), DoD cannot enter, renew, or extend contracts directly with listed companies from June 30, 2026, extending to their goods and services from June 30, 2027. It is not a ban on private purchase or use.

What is the GUARD Act? H.R. 9129, introduced June 3, 2026. It would require national-security review of humanoid and quadruped robots from foreign adversaries and place high-risk units on the FCC Covered List — with an automatic listing after one year if no determination is made, blocking import of new units. It is the mechanism that restricted DJI drones, applied to ground robots. It is not law.

Does Section 889 stop a private company from using Chinese robots? Only if the company holds or wants federal contracts. Section 889 names five Chinese electronics firms (Huawei, ZTE, Hytera, Hikvision, Dahua), not robot makers — but its Part B bars agencies from contracting with any entity that uses covered equipment anywhere in its business. A robot that embeds a covered camera or radio module can therefore cost a federal contractor its eligibility.

What happened to Chinese drones, and why does it matter for robots? On December 22, 2025, the FCC added DJI and Autel equipment plus all foreign-made drones and drone critical components to its Covered List, blocking new equipment authorizations while grandfathering deployed fleets (already-purchased units may continue operating). The GUARD Act copies this mechanism directly; the other pending bills copy the drone precedent's federal-procurement template instead — which is why the drone precedent is the best guide to how robot rules will change.

Tracker changelog

• 2026-07-24 — Page first published. Section 122 10% tariff surcharge expired by statute.
• 2026-07-22 — House passed the FY2027 NDAA including Section 163 (DoD humanoid prohibition). Senate pending. Connected Vehicle Security Act (S. 4429) advanced through Senate Commerce.
• 2026-06-30 — Section 805 direct-contracting ban on 1260H-listed companies took effect at DoD.
• 2026-06-26 — FCC used its October 2025 authority for the first time (DA 26-635), barring continued import and marketing of covered equipment listed in 2024 or earlier (deployed units may still be used).
• 2026-06-08 — Pentagon 1260H update: Unitree and RoboSense added (188 entities total; lidar maker Hesai listed since January 2024).
• 2026-06-03 — GUARD Act (H.R. 9129) introduced.
• 2026-03 — American Security Robotics Act introduced; FCC added foreign-made consumer routers to the Covered List by country of production (Mar 23).
• 2026-02 — Supreme Court struck down IEEPA tariffs (Learning Resources v. Trump, Feb 20); IEEPA layers terminated Feb 24.
• 2025-12-22 — FCC added DJI/Autel equipment and all foreign-made drones + critical components to the Covered List.
• 2025-11-20 — Humanoid ROBOT Act (S. 3275) introduced.

Sources

Primary: FAR 52.204-25 (Section 889 clause) · DoD Section 1260H list, June 8, 2026 (PDF) · FCC Public Notice DA 25-1086, Dec 22, 2025 (PDF) · FCC Public Notice DA 26-635, June 26, 2026 (PDF) · FAR 52.240-1 (American Security Drone Act clause) · 15 CFR Part 791 (connected-vehicle rule) · H.R. 9129 (GUARD Act), text at govinfo · S. 4235 (American Security Robotics Act), text at govinfo · S. 3275 (Humanoid ROBOT Act), text at govinfo · Learning Resources v. Trump (Feb 20, 2026). Secondary: WilmerHale client alert (June 11, 2026) on the 1260H update; Holland & Knight and Wiley alerts on the FCC drone action; The Wire China (Nov 2025) on Unitree's US installed base; FCC rip-and-replace figures per FCC/congressional records and trade press (June 2026); Florida fleet figures are industry estimates (2025).