Equipment that is not foreign-produced under the FCC's Covered List entries may be authorized and sold in the United States — but its non-covered status must be certified with sufficient evidence, and no regulation prescribes what that evidence is. Every manufacturer, importer, distributor, and buyer in a covered category now carries a documentation question with no published answer. This Protocol is that answer: an open, versioned standard for what a complete origin-evidence file contains, how it is verified, and how conformity may be claimed.

Download the complete Protocol — standard + Annexes A–G (PDF)

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Status: Version 1.0, Public Comment Draft, August 2026. The Protocol is free to use, cite, and require of counterparties, with attribution. Comments and adoption inquiries: [email protected]. The Protocol is maintained by Gatewell Group; verification against it may be performed by any qualified party. Conformity with this Protocol is a documentation standard — it is not an FCC, DoW, or DHS determination of any device's regulatory status, and does not guarantee any authorization outcome.

1 · Purpose and scope

The Protocol defines the contents, provenance, and maintenance of an Origin Evidence File ("OEF") for connected equipment in categories subject to the FCC Covered List — as of this version: unmanned aircraft systems and components, routers, power inverters, and advanced robotic devices. It is designed so that a regulator, certification body, insurer, or commercial counterparty examining the file can trace every origin claim to a source document, and so that the file survives the scrutiny it will only ever receive after something has gone wrong.

2 · The three conformity levels

Level 1 — DOCUMENTED. The manufacturer has assembled a complete OEF per Section 3, current within twelve months, with every element officer-attested. Self-declared.

Level 2 — VERIFIED. A qualified independent verifier has examined the OEF per the Section 4 methodology — authenticating documents, cross-checking public authorization records, and confirming a sample of supplier declarations at source — and has issued a dated verification statement identifying the Protocol version and file revision examined.

Level 3 — MONITORED. Level 2, plus standing change-control: the manufacturer maintains the Section 5 triggers, material changes are re-attested within thirty days, and the file is re-verified annually. Monitored status lapses automatically if re-verification is missed.

3 · The Origin Evidence File

3.1 Device identity. A complete schedule of covered-category models: marketing names, model numbers, FCC IDs or SDoC status, equipment classes, and authorization dates.

3.2 Production provenance. Every site performing final assembly, principal subassembly, or firmware loading for the scheduled models: legal operator, address, ownership or contractual relationship, and the production step performed. A production-flow narrative from major components to shipped unit. A signed attestation from an officer of each operating entity.

3.3 Component origin. A bill of materials for each model identifying country of origin for each line item, with deep-trace documentation — supplier declarations traced one tier up — for the components that determine the device's character in its category: radio and communications chipsets, main processors, flight controllers, power-conversion stages, and motor-control assemblies as applicable.

3.4 Corporate provenance. The manufacturer's entity chain to its ultimate parents; beneficial ownership at ten percent or greater with jurisdiction; and a dated screening of all chain entities against the current Covered List entities and their published subsidiaries and affiliates.

3.5 Software and firmware provenance. A software bill of materials in SPDX or CycloneDX format for device firmware and companion applications; the location and operator of build and code-signing infrastructure; update-server jurisdictions; and a data-flow summary identifying every endpoint the device communicates with in normal operation.

3.6 Attestation. A certification signed by an officer of the manufacturer that the file is complete and accurate as of its revision date, in the form set out in Annex A of the complete Protocol document.

4 · Verification methodology

A verifier examining an OEF at Level 2 or 3: (a) authenticates each document's source and date; (b) reconciles the device schedule against public FCC authorization records; (c) confirms not fewer than three supplier declarations, selected by the verifier, directly with the declaring supplier; (d) reconciles the corporate chain against registry filings in each named jurisdiction; (e) re-runs the covered-entity screen as of the verification date; and (f) states in writing what was examined, what was confirmed, the Protocol version applied, and the file revision covered. A verifier who provided consulting assistance in assembling a file must disclose that assistance in the verification statement.

5 · Change control

The following require re-attestation of the affected sections within thirty days, and re-verification at Level 3: a new or changed production or assembly site; a change of contract manufacturer; a sourcing change affecting any deep-trace component; any change in the corporate chain or ten-percent ownership; and any addition to the Covered List touching an entity or component in the file.

6 · Claims of conformity

Conforming parties may state: "[Company]'s Origin Evidence File for [models] conforms to the Gatewell Protocol for Origin Evidence, Version 1.0, at Level [1/2/3], as of [date]." Claims must name the level and date, may not be applied to models outside the verified schedule, and may not state or imply endorsement by any government agency. Buyers and importers are encouraged to require a stated level and current date from counterparties as a condition of qualification.

6a · The conformity marks

Marks may be displayed only with a current certificate ID from the registry, per Section 6. Verified parties receive the mark kit with their certificate.

7 · Maintenance

The Protocol is versioned. Substantive changes are published with a comment period and a dated changelog; files verified under a prior version remain valid to that version's terms until their next re-verification. Regulatory developments — including any future prescribed documentation standard — will be incorporated by revision, and the Protocol will yield to any mandatory standard on its effective date.

Working with the Protocol. The standard is free and always will be. Gatewell Group provides OEF assembly, Level 2 verification, and Level 3 monitoring as engagements — and buyers who wish to require the Protocol of their vendor bench can adopt it by reference at no cost. Start with a conversation: request a diagnostic or write [email protected].

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© 2026 Gatewell Group. The Protocol text may be reproduced and distributed with attribution, unmodified. "Gatewell Protocol" designation reserved. Regulatory context verified against FCC sources as of August 7, 2026; the regime changes frequently — confirm current requirements before relying on any element of this document. This document is not legal advice.