The FCC’s changes to its equipment authorization program have advanced beyond the proposal stage covered in NexPCB’s earlier policy update.
According to the China Academy of Information and Communications Technology’s regulatory update, the U.S. Federal Communications Commission adopted FCC 26-73 on October 29, 2026, and released the order on October 30. The update confirms restrictions on recognizing testing laboratories and certification bodies located in non-Reciprocal Economies, with a transition deadline of December 1, 2028.
Which Organizations Are Covered?
The announced recognition restrictions cover three types of organizations involved in the equipment authorization process:
- Testing laboratories;
- Telecommunication Certification Bodies (TCBs);
- Laboratory accreditation bodies.
The policy concerns organizations located in non-Reciprocal Economies—countries or territories without a Mutual Recognition Agreement or a comparable reciprocal agreement with the United States.
For electronics manufacturers serving the U.S. market, the central change concerns the eligibility of organizations performing formal testing, certification, and accreditation work. A laboratory’s participation will depend on the applicable FCC recognition requirements.
The Location of the Work Also Matters
The FCC’s published meeting notice described requirements addressing both organizational recognition and the location of substantive activities supporting equipment authorization. It outlined a framework under which qualifying testing, certification, and accreditation activities would take place in the United States or a Reciprocal Economy.
An overseas TCB’s involvement does not, by itself, establish that the underlying testing meets the applicable requirements. The laboratory performing the formal testing and the certification body reviewing the application have separate roles in the authorization process.
Pre-compliance testing and engineering troubleshooting can help identify technical issues during development. These activities cannot substitute for the formal testing required to support an FCC Certification application.
Understanding the December 2028 Transition
The announced transition deadline is December 1, 2028. China’s official regulatory update identifies this as the enforcement date for withdrawing recognition from laboratories in non-Reciprocal Economies.
The FCC’s meeting notice described the transition period as allowing manufacturers time to establish alternative testing arrangements and eligible laboratories time to expand capacity.
This transition date should be distinguished from the legal effective dates of individual provisions. The announcement also does not establish a standard increase in certification cost or turnaround time for every product.
Certification, SDoC, and Product Changes
FCC Certification and Supplier’s Declaration of Conformity (SDoC) remain separate equipment authorization procedures.
Under 47 CFR § 2.906, SDoC carries its own compliance requirements, including restrictions on testing facilities owned by, controlled by, or under the direction of prohibited entities. A general statement that SDoC testing remains unrestricted in mainland China would therefore be inaccurate.
Changes to certified products are separately governed by the applicable FCC modification rules. Depending on the modification, these may permit a permissive change or require a new certification application.
A Further Update from NexPCB
Will changes in testing locations affect certification lead times? How will sample shipments, technical communication, and retesting arrangements work in practice?
These questions require discussions with testing and certification partners. NexPCB will share a follow-up after collecting and confirming supplier feedback, covering practical changes to testing arrangements, implications for project schedules, and our corresponding support plans.
Sources: CAICT regulatory update referencing FCC 26-73; FCC October 29, 2026 meeting notice, published in the Federal Register; 47 CFR § 2.906 and § 2.1043.
Related FCC document: FCC 26-73 — Third Report and Order and Third Further Notice of Proposed Rulemaking.
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