On November 25, 2025, The U.S. Federal Communications Commission (FCC) is closing loophole in its national security regulations, issued a Second Report and Order, effective December 26, 2025. In a Final Rule that has clarified that its ban on “covered” equipment extends to the very components used inside host products, which has implications for any device manufacturer using modular transmitters.
The Modular Loophole Is Officially Closed
For years, manufacturers have relied on pre-certified modular transmitters to streamline the FCC authorization process for their own products. The new rule slams that door shut for any modules originating from companies on the FCC’s Covered List.
The clarification is twofold and unambiguous:
- No New Authorizations for Covered Modules: Modular transmitters that are themselves considered “covered equipment” are now explicitly prohibited from receiving an FCC equipment authorization.
- Host Devices Are Also Banned: Crucially, the FCC now also prohibits the authorization of any host device that includes a covered modular transmitter, regardless of whether that module was previously certified.
In simple terms, you can no longer use a pre-certified but “covered” radio module and expect your final product to get FCC approval. The attestation you make during the certification process now applies to these critical internal components.
Sunsetting the Past: Limiting Existing Authorizations
What about the thousands of devices already certified that contain these now-prohibited modules? The FCC is not issuing a full-scale recall. Instead, it is adopting a more targeted approach to “limit” previously granted authorizations.
This new procedure empowers the FCC to prohibit the continued importation and marketing of specific covered equipment. This allows devices already in the hands of consumers to remain in use but effectively stops the flow of new products into the U.S. supply chain.
What This Means for Your Product Certification
The integrity of your supply chain is now a core part of your compliance obligations.
- Audit Your Bill of Materials (BOM): It is now imperative to know the origin of every component in your device, especially RF modules. Using a module from a company on the Covered List will result in a rejected FCC application.
- Re-Evaluate Your Designs: If your products currently rely on modules from a covered supplier, you must begin the redesign and re-certification process with a compliant alternative immediately.
- Attestation Carries More Weight: When you attest that your device is not “covered equipment,” you are now also attesting to the compliance of its integrated modular transmitters.
