How the FCC’s Secure Networks Act Is Intensifying Trade Compliance for U.S. Businesses

Trade compliance has emerged as a major priority for many U.S. businesses over the past few years. The Trump administration has implemented an aggressive and ever-evolving tariff regime, the U.S. and China have each carried out a succession of trade controls aimed at weakening the other, and ethical sourcing regulations like the UFLPA have imposed new restrictions on how companies can build out their supply chains.

In the past 12 months, though, a new development in trade compliance has quietly taken shape, one that could have profound implications for the way American companies import electronic components, sub-assemblies, and finished electronic products. Over the remainder of the decade, U.S. importers may find themselves operating with significant new limitations when it comes to sourcing essential technological hardware from foreign countries like China.

It all starts with a relatively obscure regulation, signed into law in 2020, that is on the cusp of seeing its profile surge: the Secure and Trusted Communications Networks Act of 2019.

What Is the Secure Networks Act?

Passed by Congress in 2019 and signed into law by President Trump in March 2020, the Secure and Trusted Communications Networks Act (the “Secure Networks Act”) aims to prohibit federal funding for communications equipment and services that pose a national security risk from entering the U.S. market and the networks that lie within it. In tandem with the 2022 Secure Equipment Act, the Secure Network Act effectively bans the import and sale of listed communications equipment and services by requiring the Federal Communications Commission (“FCC”) to refuse to certify listed equipment entering the United States.

Because FCC certification is a requirement for any radio-frequency devices to be imported into and sold within the United States, this results in a de facto sale and import ban for all new equipment from “Covered List” vendors and product categories. Import and sale of equipment authorized before a product or vendor was placed on the covered list remains legal—with a key exception discussed below.

To be placed on the FCC’s “Covered List,” a U.S. government agency must determine that the equipment either:

• Routes, redirects, or permits visibility into user data traffic.

• Is capable of causing remote network service disruption.

• Otherwise poses an unacceptable national security risk.

In March 2021, the government published an initial list of products covered by the Secure Networks Act. Starting on that date, U.S. businesses were prohibited from importing any of the products listed below.

Following the publication of the inaugural list of covered entities under the Secure Networks Act, the government continued adding additional foreign entities. From 2022 through 2024, the Federal Communications Commission added the following foreign businesses to the SNA’s Covered List:

• AO Kaspersky Lab

• China Mobile International USA Inc.

• China Telecom (Americas) Corp

• Pacific Networks Corp and subsidiary ComNet (USA) LLC

• China Unicom (Americas) Operations Limited

As these lists illustrate, the first four years of the Secure Networks Act were targeted and limited, focusing exclusively on telecommunications devices, surveillance equipment, and antivirus software manufactured by a handful of Chinese and Russian businesses that the FCC determined posed a threat to U.S. national security.

Once we reached the end of 2025 and moved into 2026, however, that scope grew quickly, dramatically shifting the role and influence of this seemingly niche trade law.

Why Has 2026 Been So Monumental for the Secure Networks Act?

Though the Secure Networks Act has been around for over six years, for most of that time it was of interest only to telecommunications and surveillance equipment manufacturers, including manufacturers of mobile phones, and importers of that equipment. That all changed in 2026.

Since the end of 2025, the Federal Communications Commission—the agency responsible for administering the SNA—has worked in tandem with other national security agencies to expand the scope and impact of the Covered List in a number of critical ways. First, from December 2025 to July 2026, the FCC added four full product categories to the Covered List, effectively barring those items from being imported by U.S. businesses unless granted a conditional approval by the Department of Homeland Security or the Department of War. “Where the Covered List once was limited to telecommunications and surveillance products sold by a handful of vendors, it has now been expanded to cover connected devices in seemingly unrelated industries—and to capture products manufactured by any foreign vendor within those industries unless the manufacturer obtains an exception,” Lindsay Wardlaw, trade compliance lawyer and the founder of Wardlaw Trade Law, said.

Timeline of Product Categories Added to Secure Networks Act

• December 22, 2025: The Federal Communications Commission adds uncrewed aircraft systems (UAS)—which often take the form of drones—and critical UAS components produced in a foreign country to the Covered List (with some exceptions).

• March 23, 2026: The FCC adds routers produced in a foreign country to the Covered List.

• July 28, 2026: The FCC adds power inverters produced in a foreign country to the Covered List.

• July 28, 2026: The FCC adds robotic devices produced in a foreign country to the Covered List.

On its surface, this would appear to be a monumental development for U.S. companies, given the degree to which American industry relies on a wide swath of technological hardware produced in foreign countries. If manufacturers can’t import foreign routers, for example, then they may have to pivot to domestic manufacturing, or ask their foreign producers to seek conditional FCC authorization if they want to avoid major stoppages.

The second major change to the Secure Networks Act in 2026 may be even more consequential. On October 13, 2026, the Federal Communications Commission will expand its interpretation of the SNA’s scope to include “logic-bearing hardware components” that are incorporated into products on the Covered List. When this rule takes effect, it will mean that when foreign-made products like drones, robotics, routers, and other equipment are placed on the Covered List, then the inclusion of foreign-produced logic-bearing components may cause even U.S.-produced goods to be subject to the same marketing prohibitions as foreign-produced finished products.

A third major change to the FCC’s enforcement of the Secure Networks Act comes through an October 2025 FCC rule allowing the agency to prohibit the continued importation or marketing of previously authorized equipment. Using this authority, the FCC has now prohibited the importation and marketing of all equipment added to the Covered List in 2024 or earlier. This means that even older, pre-2021 equipment from covered vendors is now effectively banned from entering the U.S. market. The FCC has not yet issued comparable bans for more recent categories of Covered List equipment, but it retains the authority to do so. “Companies relying on older-model equipment from vendors or industries on the Covered List should take note,” said Wardlaw. “They may want to consider building their procurement strategies so that they’re not heavily reliant on equipment that they could, at any moment, be unable to restock, purchase spare parts for, or send abroad for repairs.”

The Critical Exceptions

U.S. businesses familiarizing themselves with the Secure Networks Act for the first time might be taken aback, even shocked, to learn about such sweeping import restrictions of fundamental technological equipment. But although recent national security determinations have placed a number of major product categories used across myriad industries onto the Covered List, the FCC has also extended some exceptions that will make the SNA more palatable to American businesses.

The FCC maintains a list of foreign companies that have been granted “conditional approval” to continue selling their Covered List products and components in the U.S. market. These exemptions cover routers, UAS, and robotics, and are published on the FCC website. The lists of conditional approvals include major manufacturers, including:

• Netgear

• Nokia

• Alpha

• SpaceX

• Husqvarna

These businesses control a significant percentage of the markets for their respective covered categories.

One key caveat to bear in mind with these conditional approvals, however, is that they’re not permanent—most companies on these lists have exemptions that expire in 2027 or 2028. As Wardlaw pointed out, these conditional approvals might be the U.S. government’s way of using its leverage as a market gatekeeper to compel foreign businesses to modify their manufacturing networks. “It’s possible that the U.S. government will withhold continuing conditional approval on a manufacturer’s ability to avoid certain supply chain nodes that the government finds problematic,” she said.

Thus far, the full motivation behind the Trump administration’s decision to aggressively expand the Secure Networks Act and use the FCC to administer the regulation has been difficult to parse. But considering the covered entities and the new product categories, it’s all but certain that the government wants to compel American companies to start extricating themselves from Chinese supply chains. While noting that the latest Covered List categories are not limited to items produced in China or by a Chinese manufacturer, Wardlaw said, “I think the underlying current of all of this is our increasing concern about electronic components made in China.”

What the Expanded SNA Means for U.S. Manufacturers

So what does the Secure Networks Act and all these layered, arguably conflicting developments mean for American businesses? Is the impetus now on U.S. importers to start moving away from manufacturing in China and other adversarial nations, and looking to domestic producers for drones, routers, robotics, and the parts that go into their bills of materials (BOMs)?

Given the conditional approvals granted by the FCC, it would seem that the Trump administration is not interested in spurring a sourcing and procurement crisis for American producers that rely on foreign vendors. Rather, the goal of the expansions to the SNA may be to make manufacturers think twice about basing their production in a higher-risk jurisdiction like China, and to make their customers more wary of depending on foreign-produced goods. “All things being equal, it may be safer to find a U.S. vendor than rely on a foreign vendor with a conditional approval when you’re thinking about your long-term purchasing strategy,” Wardlaw said.

In addition, businesses that have greater visibility into their direct and sub-tier suppliers will have an easier time demonstrating to U.S. regulators that their goods were not produced—in part or whole—by covered entities or adversarial nations. “For suppliers seeking conditional approval, if you can show that your product doesn’t have supply chain nodes of concern with foreign adversarial countries, that would be helpful,” Wardlaw pointed out.

For businesses that rely on large numbers of drones, routers, and robotics devices for their products, services, or operations, the strategic questions they face around sourcing and procurement are growing more complicated. Companies may want to start focusing on ways to maximize the lifespan of their current imported products and components, as the new restrictions don’t affect models of these items approved for sale in the U.S. before their industries were added to the Covered List—yet. “If you are somebody who relies on these products, I think you have to start thinking about whether you have a stable supply for now, and whether you have replacement parts stocked up in case they become unimportable in the future,” Wardlaw said.

This type of risk management approach can buy companies time to explore more permanent solutions, including nearshoring, reshoring, or establishing supply chain connections with countries other than China. “Chinese parts are probably the main target of this regulation,” Matthew Warren, supply chain risk management solutions specialist at Z2, said. “So you might consider trying to purchase parts coming from, say, Vietnam, the Philippines, Malaysia, or somewhere else in the ASEAN region.”

Managing Compliance Risks With Visibility and Expertise

While there’s still a fair amount of uncertainty around how the Secure Networks Act will ultimately impact U.S. importers, a few details appear unequivocally clear.

First, American businesses concerned about these new trade restrictions will benefit from being able to identify and assess alternative manufacturers and suppliers that will free them from the instability and tenuousness of sourcing from a foreign company squarely inside the SNA’s crosshairs. Second, only companies with robust supply chain visibility will be able to understand their level of exposure with the nuance required to effectively navigate this complex law.

Supply chain risk management (SCRM) software Z2 offers businesses the data and capabilities to do both. Z2 can help companies trace individual components in their BOMs to their manufacturing source, shedding light on what products and parts are at risk of violating the SNA—now or in the future. In addition, Z2 offers an expansive database of over one million suppliers, including risk scorecards that evaluate the businesses across eight critical categories that include financial health, geopolitical exposure, sourcing dependencies, and trade compliance. For companies looking to modify their supply chains to achieve greater compliance with the SNA, this database can function as a powerful resource.

To learn about how Z2 can help businesses navigate the Secure Networks Act and all the compliance implications of this growing regulation, schedule a free trial with one of our product experts.