FCC Enacts New Integrity Rules and Foreign Lab Restrictions for Equipment Authorization

The U.S. Federal Communications Commission (FCC) initiated Notice of Proposed Rulemaking ET Docket No. 24-136, titled Promoting the Integrity and Security of Telecommunications Certification Bodies, Measurement Facilities, and the Equipment Authorization Program, establishing tighter oversight over foreign testing entities. The action sought to address national security vulnerabilities within the equipment authorization pipeline by preventing entity-level manipulation, mitigating intellectual property theft, and closing compliance loopholes used by untrusted foreign manufacturers seeking U.S. market access. Under the initial regulatory proposal, the FCC targeted Telecommunications Certification Bodies (TCBs) and accredited test laboratories influenced or controlled by entities on the FCC’s Covered List.

Building directly on this regulatory docket, the FCC finalized landmark rules under Report and Order FCC 26-28, significantly reshaping foreign test lab recognition and certification workflows. Effective mid-2026, the updated framework establishes a phase-out of FCC recognition for accredited test laboratories, TCBs, and accreditation bodies operating in non-reciprocal foreign territories—specifically countries that lack a Mutual Recognition Agreement (MRA) or equivalent bilateral trade agreement with the United States. Furthermore, TCBs and testing facilities must now submit mandatory disclosures detailing the geographic location and foreign staff involved in regulatory testing and review activities. To enforce compliance, the agency established a secure portal for confidential violation reporting, directed the creation of a consolidated prohibited entities list, and modernized post-market surveillance procedures.

To encourage compliance and reduce processing bottlenecks, the FCC instituted a fast-track priority review pathway under the Pre-Approval Guidance (PAG) process for equipment tested at "Trusted Test Labs"—defined strictly as facilities located within the United States or an MRA partner nation. Conversely, device testing conducted in non-reciprocal regions faces heightened scrutiny and a phased prohibition timeline. Original equipment manufacturers (OEMs), testing laboratories, and importers targeting the U.S. wireless market must audit their supply chains immediately and transition testing workflows to domestic or MRA-recognized facilities to ensure uninterrupted equipment authorizations.

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