When the phones are in a no-service area and display an "out of range" message, they could fail to connect to 911, the agency said.
A Federal Communications Commission rule requires that a wireless phone have the capability to reach a 911 center even when out of service range. The phone should be able to piggyback off another service provider in the area to get to 911.
The company is contacting consumers directly to schedule a free software upgrade.
Consumers can call Samsung at 866-304-4980 if they have not already been contacted.
The phones were manufactured by Samsung Telecommunications America, based in Texas. They were sold between March 2008 and May 2009 for about $150.
The model numbers are: SPH-a110 and SPH-a120 with standard key pads and version BB14 software.