FCC’s New Device Test Lab Onshoring and Reciprocity Mandates
On October 29, 2026, the Federal Communications Commission issued a final order altering the regulatory guidelines that oversee testing laboratories involved in equipment authorizations. Prior to commercializing or utilizing electronic devices that fall under FCC equipment authorization rules in the United States, necessary testing must be executed by a laboratory recognized by the FCC.
The new order restricts FCC accreditation of testing facilities, Telecommunications Certification Bodies, and laboratory accreditation bodies strictly to the United States and designated Reciprocal Economies (regions that provide mutual recognition and fair market access to U.S.-based labs).
Key Highlights of the Final Order (FCC 26-73)
Scope of Limitations: Official recognition is confined exclusively to testing facilities, Telecommunications Certification Bodies, and accreditation bodies situated within the U.S. or in countries bound to the U.S. through Mutual Recognition Agreements, Free Trade Agreements, or Agreements on Reciprocal Trade featuring robust reciprocity terms.
Transition Period: A uniform transition window ending on December 1, 2028, has been put in place to give manufacturers and labs sufficient time to adapt. Any applications filed on or after that date must rely strictly on testing and certification that comply with the updated rules.
Grandfathering Existing Grants: Equipment certifications secured prior to December 1, 2028, remain completely valid and will not be forced to undergo retesting solely due to changes in a lab's recognition status.
Combating Overconcentration and Security Risks: The FCC pointed out that nearly five out of every six radiofrequency devices have been tested in foreign, non-reciprocal jurisdictions. This trend has introduced critical supply chain vulnerabilities, intellectual property theft hazards, and monitoring difficulties. Reintroducing reciprocity rebuilds regulatory control and safeguards domestic communication systems.
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