Regulatory Scope of FCC Certification Pre-Approval Guidance
On September 30, 2026, the Federal Communications Commission (FCC) Laboratory Division published KDB Publication 388624 D02 v18r09. This official document replaces version v18r08 immediately. Consequently, Telecommunication Certification Bodies (TCBs) must follow these revised rules prior to issuing product grants. Compliance engineering teams need to understand how these updates alter the FCC certification pre-approval guidance workflow for high-frequency technologies.
Updated Scope for High-Frequency Equipment Approvals
First, the revision introduces a mandatory review step for Sub-THz technology. Specifically, devices operating above 95 GHz under Part 15.258 or Part 18 must complete the new SUBTHZ Pre-Approval Guidance (PAG) process before grant issuance.
Conversely, the FCC eliminated pre-grant review barriers for mature wireless products. The Commission completely voided submission requirements for OVER6G (RF exposure above 6 GHz) and UWB15F (hand-held UWB under § 15.519). Furthermore, officials narrowed the UN6GHZ PAG scope exclusively to Geofenced Variable Power (GVP) devices in the 5.925–6.425 GHz and 6.525–6.875 GHz bands. As a result, standard 6 GHz client devices and indoor access points skip the extra pre-approval review entirely.
Testing Requirements and Documental Dependencies
These new rules directly impact testing procedures and documentation submittals. For Sub-THz filings, test reports must reference ANSI C63.10-2020 and KDB Publication 800303. Additionally, laboratories must document environmental conditions, record atmospheric attenuation factors, and apply FMCW correction factors. Applicants must also select equipment class THZ or 8TZ on Form 731 and verify that the test lab holds accreditation up to 750 GHz.
However, manufacturers of standard Wi-Fi 6E devices, UWB location tags, and portable transmitters between 6 GHz and 8.5 GHz gain significant benefits. The removal of extra FCC inquiries shortens overall market access timelines for these product lines.
Action Items for Regulatory Compliance Teams
Effective immediately, compliance experts must update internal test checklists and align TCB submittal workflows. Additionally, managers must verify lab accreditation scopes for ultra-high-frequency product lines. The update introduces no physical labeling or user manual changes. Nevertheless, teams launching products above 95 GHz must account for mandatory PAG review steps in their production schedules.
Streamline Your Type Approval and Equipment Authorization Workflows
Navigating complex regulatory changes and equipment authorization frameworks requires proactive planning. Learn how our Product Certification Service can manage your submittal workflows, coordinate with TCBs, and ensure seamless market entry.
Impact Assessment
-
Technical Standards? ✅ Yes
-
Type Approval & Market Access? ✅ Yes
-
Imports, Customs, Trade, or Market Surveillance? ❌ No
-
Spectrum Management? ❌ No
