From December 2028, FCC certification testing will be restricted to recognised laboratories in the United States or countries with reciprocal agreements.
At a glance
· The FCC has adopted new rules restricting the recognition of test laboratories, certification bodies and accreditation bodies in non-reciprocal countries.
· The restrictions take effect on 1 December 2028, giving manufacturers a transition period.
· Existing FCC authorisations will remain valid, but manufacturers may need to review their testing and certification arrangements for future applications.
What has the FCC changed?
On 29 October 2026, the US Federal Communications Commission (FCC) adopted new rules limiting which laboratories can participate in its equipment authorisation programme.
Under the FCC Third Report and Order (FCC 26-73), recognition will be restricted to test laboratories, Telecommunications Certification Bodies (TCBs) and laboratory accreditation bodies located in the United States or in countries with applicable reciprocal recognition agreements.
The decision aims to strengthen oversight, testing integrity and security within the FCC equipment authorisation system.
Which countries and laboratories remain eligible?
The new framework permits recognised laboratories in the United States and Reciprocal Economies — countries covered by a Mutual Recognition Agreement (MRA) or comparable reciprocal trade agreement with the US.
The European Union is covered by an existing MRA, meaning appropriately accredited and FCC-recognised EU laboratories can continue supporting FCC certification.
However, eligibility depends on more than the laboratory’s registered address. Substantive certification-related activities, including required measurements, technical analysis and test report preparation, must also take place in permitted locations.
The restrictions do not prohibit equipment manufacturing in non-reciprocal countries or independent R&D and pre-compliance testing that is not used for FCC certification.
What happens to existing FCC certifications?
The new restrictions apply to equipment authorisation applications received on or after 1 December 2028.
FCC certifications granted before that date will not automatically become invalid because of the laboratory location changes. Applications received before the deadline are also covered by the transition arrangements.
Manufacturers planning new certifications after December 2028 should therefore confirm that their selected testing laboratories and certification partners will remain eligible.
The FCC has separately sought comments on further changes to Supplier’s Declaration of Conformity (SDoC) testing. Those additional proposals should not be confused with the rules already adopted.
Testilabs view: What should manufacturers do now?
For manufacturers relying on overseas laboratories, the key consideration is where future FCC certification testing will be performed.
Companies should review:
· Laboratory recognition: Confirm whether their current test laboratory will remain FCC-recognised after December 2028.
· Actual testing location: Verify where certification measurements, technical evaluations and test report preparation are performed.
· Future certification projects: Identify alternative recognised laboratories in the US or reciprocal countries where necessary.
· Project planning: Consider testing capacity and lead times when scheduling new FCC approvals around the transition.
For manufacturers developing products for multiple markets, an existing global testing arrangement should not automatically be assumed to remain suitable for future FCC submissions.
Reviewing laboratory eligibility early can help avoid unexpected retesting, additional costs and certification delays.
Related Testilabs services: FCC/ISED Certification · EMC & RF Testing
