The U.S. Federal Communications Commission (FCC) has introduced significant updates to its equipment authorization framework, signalling a shift toward tighter control over global testing practices.
Through a combination of newly adopted rules and a proposed rulemaking, the FCC aims to restrict the use of certain foreign testing laboratories while accelerating approvals for devices tested in trusted jurisdictions. These changes are intended to strengthen national security, reinforce reciprocity in international certification systems, and improve the integrity of the FCC’s equipment authorization process.
For manufacturers seeking access to the U.S. market, these developments will have direct implications on testing strategies, certification timelines, and overall compliance planning.
Regulatory Background
The FCC equipment authorization program requires electronic devices to undergo testing and certification prior to being marketed in the United States. This process relies on recognised testing laboratories and certification bodies, both within the U.S. and internationally.
Historically, the FCC limited recognition to laboratories located in the United States or in countries with Mutual Recognition Agreements (MRAs), ensuring reciprocal acceptance of testing and certification systems. The latest action reflects a return to this principle, with a renewed emphasis on security, oversight, and regulatory control.
Key Regulatory Developments
Proposed Restrictions on Non-Reciprocal Test Labs
The FCC has issued a Notice of Proposed Rulemaking seeking comment on prohibiting the recognition of testing laboratories and certification bodies located in countries that do not maintain reciprocal agreements with the United States.
If adopted, this proposal would require manufacturers to conduct testing in:
- The United States, or
- Countries with MRAs or comparable reciprocal arrangements
The FCC has indicated that this approach is intended to restore reciprocity and strengthen the reliability of the equipment authorization system.
Proposed Transition Period
As part of the proposal, the FCC has indicated that affected laboratories would be subject to a phase-out period of up to two years following the adoption and implementation of any final rules.
This transition would allow manufacturers time to adjust their testing strategies and shift to recognised laboratories.
Fast-Track Approval for Trusted Labs (Adopted)
Alongside the proposed restrictions, the FCC has adopted new measures to streamline the approval process for devices tested in trusted laboratories.
A priority review process will apply to devices tested in:
- U.S.-based laboratories
- Laboratories located in countries with reciprocal agreements
This measure is designed to incentivise the use of trusted testing facilities and reduce approval timelines for compliant applications.
Increased Transparency Requirements
The FCC has introduced additional disclosure requirements for recognised testing entities. These include providing more detailed information on:
- The location of testing facilities
- The number of personnel involved in testing activities
These requirements aim to improve transparency and traceability within the certification process.
Strengthened Surveillance and Enforcement
The FCC is also enhancing its post-market oversight framework. The adopted measures include:
- Expanded post-market surveillance procedures
- Strengthened enforcement mechanisms
- The introduction of confidential reporting channels for industry participants
Together, these changes reflect a more proactive approach to monitoring compliance and addressing potential risks after products enter the market.
Continued Action on High-Risk Laboratories
These updates build on prior FCC actions addressing national security concerns within the testing ecosystem. The Commission has previously adopted rules to prohibit recognition of laboratories owned or controlled by foreign adversaries and has already taken action against multiple high-risk facilities.
According to the FCC, recognition has been withdrawn from or denied to 23 laboratories identified as posing security risks.
Industry Impact
The FCC’s latest actions introduce a structural shift in how manufacturers approach product certification for the U.S. market.
Manufacturers relying on global testing networks may need to reassess whether their current laboratories will remain recognised under the proposed framework. A transition toward U.S.-based or MRA-recognised laboratories may be required, which could impact both cost and testing capacity.
At the same time, the introduction of a fast-track approval pathway presents an opportunity to reduce time-to-market for companies that align with trusted testing jurisdictions. However, increased transparency requirements and strengthened post-market surveillance also mean that compliance obligations will extend beyond initial certification.
As a result, early planning and proactive regulatory strategy will be critical to navigating these changes effectively.
To read the official FCC notification, access below.
How C-PRAV Can Support You
C-PRAV Labs and Certifications provides comprehensive support to help manufacturers adapt to evolving FCC requirements, including:
- Regulatory impact assessment and certification strategy development
- Identification and coordination of recognised and compliant testing laboratories
- End-to-end support for FCC equipment authorization processes
- Guidance on transitioning testing to approved jurisdictions
- Ongoing monitoring of FCC rulemaking and regulatory developments
Our expertise enables manufacturers to maintain compliance, minimise disruption, and ensure efficient access to the U.S. market.