FCC Expands Equipment Authorization Safeguards Against National Security Threats

The Federal Communications Commission adopted significant updates to its equipment authorization framework under Docket No. 21-232 to close existing regulatory loopholes and prevent untrustworthy telecommunications equipment from entering the U.S. supply chain. Building on the foundation established by the Secure Equipment Act and the Commission’s Covered List restrictions, the updated measures expand the scope of prohibited devices and establish strict compliance requirements for component manufacturers, equipment integrators, and online sales platforms. These rules ensure that equipment poses no national security risks before receiving regulatory approval or market access in the United States.

Under the revised framework, the FCC extended authorization prohibitions beyond finished standalone devices to include logic-bearing hardware components produced by entities on the Covered List. Devices incorporating restricted microprocessors, integrated circuits, or modules from covered suppliers—such as Huawei, ZTE, Hikvision, Dahua, or Hytera—are strictly barred from receiving FCC certification. Furthermore, the Commission clarified that modifying previously certified equipment that incorporates covered components or software requires a complete recertification process, prohibiting the use of permissive changes to circumvent security reviews. To enforce these requirements at the point of sale, online marketplaces listing third-party electronic devices must ensure compliance with marketing rules, including prominently displaying valid FCC IDs for all listed equipment.

To maintain continuous supply chain integrity, applicants seeking equipment authorizations must now submit detailed Hardware Bill of Materials (HBOM) and Software Bill of Materials (SBOM) disclosures during the certification process. Telecommunication Certification Bodies and accredited testing laboratories are required to verify these documentation submittals prior to issuing equipment grants. By closing component-level loopholes and mandating end-to-end transparency across supply chains, the FCC reinforces national security standards for radio frequency devices and ensures robust protection across commercial and consumer electronics operating within the United States.

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