On October 29, 2026, the Federal Communications Commission (FCC) adopted new FCC Test Lab Rules that will reshape electronic device testing for the U.S. market. The Commission approved the Third Report and Order and Third Further Notice of Proposed Rulemaking (FCC 26-73) through a unanimous 3–0 vote.
The decision introduces new location requirements for testing laboratories, certification bodies, and accreditation organizations. It also establishes a transition period that gives manufacturers time to adapt their testing arrangements before December 2028.
FCC Test Lab Rules: New Recognition Requirements
Under the new framework, the FCC will recognize testing laboratories, Telecommunication Certification Bodies (TCBs), and laboratory accreditation bodies only in the United States or Reciprocal Economies. These economies maintain a Mutual Recognition Agreement or a comparable reciprocal arrangement with the United States.
Additionally, the rules require organizations to conduct their substantive testing, certification, and accreditation activities within these eligible jurisdictions. Through these measures, the FCC aims to strengthen regulatory oversight, improve accountability, and promote reciprocal recognition across international markets.
Transition Period and December 2028 Deadline
The FCC has established a transition period for laboratories operating in non-reciprocal economies. These facilities may retain their existing recognition until December 1, 2028, when the new restrictions will end their eligibility.
This timeline gives manufacturers approximately two years to review their testing arrangements and identify alternative facilities. Therefore, companies that rely on laboratories in non-reciprocal countries should evaluate their options before the deadline to reduce potential disruptions.
Implications for International Testing Operations
The decision could significantly affect manufacturers that rely on international testing facilities. According to the FCC, fewer than 4% of electronic devices undergo testing in U.S. laboratories. Meanwhile, a substantial share of testing takes place in countries without reciprocal arrangements.
Mainland China does not qualify as a Reciprocal Economy under the new framework. Consequently, manufacturers using laboratories in these jurisdictions may need to reconsider their testing strategies and identify eligible alternatives.
Moreover, demand for testing services in the United States and Reciprocal Economies could increase as the transition deadline approaches. Early planning may help manufacturers secure laboratory capacity and maintain continuity in their equipment authorization processes.
Additional FCC Proposals and Public Consultation
Alongside the final rules, the FCC adopted a Third Further Notice of Proposed Rulemaking. This notice seeks public feedback on additional measures, including potential ownership-related restrictions for testing laboratories and TCBs.
The public comment period will close 30 days after the Federal Register publishes the notice. However, these additional proposals remain under consideration and do not constitute final regulatory requirements.
What Manufacturers Should Consider
Manufacturers seeking FCC equipment authorization should review their current testing partnerships and determine whether their laboratories operate in eligible jurisdictions. In addition, they should assess alternative testing options and plan for the December 2028 transition deadline.
As regulatory requirements evolve, companies must monitor developments that could affect their certification strategies. Entirety’s Product Certification Service supports manufacturers navigating product certification, regulatory compliance, and international market access requirements.
Regulatory Impact Assessment
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Technical Standards?
No -
Type Approval & Market Access?
Yes -
Imports, Customs, Trade, or Market Surveillance?
No -
Spectrum Management?
No
