FCC Equipment Authorization — Foreign Test Labs & TCB Restrictions

Current understanding

The FCC has issued a proposed rule to stop recognizing test laboratories, Telecommunications Certification Bodies (TCBs), and laboratory accreditation bodies located in countries that lack a Mutual Recognition Agreement (MRA) or trade agreement with the United States, citing national security and intellectual property protection in the equipment authorization program. If finalized, importers and manufacturers of RF/wireless equipment would need to obtain testing and certification from labs in MRA/trade-agreement jurisdictions, potentially shifting compliance costs and lead times. Status: proposed rule (NPRM); comment and final-rule stages pending.

Evidence log

• 2026-05-20 — Blocking CCP Spy Tech Act of 2026: cross-connection with blocking-ccp-spy-tech-act-2026: Both target Chinese-origin surveillance/spy technology entering U.S. networks, with S4586 pursuing a legislative restriction and the FCC NPRM pursuing a parallel conformity-assessment channel. (novelty: 2)
• 2026-05-15 — Promoting the Integrity and Security of Telecommunications Certification Bodies, Measurement Facilities, and the Equipment Authorization Program: cross-connection with icts-supply-chain-security-act-s4882: Both extend ICT national-security controls into supply chains: S4882 via covered-transaction authorities and the FCC NPRM via gatekeeping which foreign labs and TCBs may certify equipment for U.S. import and sale. (novelty: 3)

Open questions

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