The Federal Communications Commission (FCC) release of its Small Entity Compliance Guide on September 4, 2025, the FCC is clarifying the real-world impact of its new national security rules, and the ripple effects will be felt by every manufacturer seeking access to the U.S. market.
It directly targets the Telecommunications Certification Bodies (TCBs), test labs, and accreditation bodies.
Banning “Prohibited Entities”
The core objective of the underlying FCC order (FCC 25-27) is to protect the U.S. supply chain. To do this, the FCC is banning any TCB, test lab, or accreditation body that is owned or controlled by entities deemed a threat to national security.
The rules are clear:
- An organization is considered “owned by” a prohibited entity if that entity holds 10% or more of its equity or voting interest.
- Any TCB or lab that meets this criterion will be prohibited from participating in the FCC’s equipment authorization program.
For manufacturers, the implication is staggering: the test report you just paid for could become worthless if your lab is found to be non-compliant.
The New Mandates: Certification and Reporting
To enforce this, the FCC has established new, strict reporting and certification requirements for all recognized TCBs and test labs. This is where the guide’s clarifications become critical.
- The Integrity Pledge: Within 30 days of the rules taking effect, every recognized lab and TCB must formally certify to the FCC that they are not owned or controlled by a prohibited entity.
- The Ownership Reveal: Within 90 days, they must also report to the FCC all equity or voting interests of 5% or greater.
- The SDoC Connection: Crucially, these rules also apply to labs used for Supplier’s Declaration of Conformity (SDoC) testing. A manufacturer must now maintain a signed certification that their SDoC test lab was compliant as of the date of testing.
What This Means For Manufacturer
The integrity of your certification is now directly tied to the compliance of your partners. The days of simply picking a lab and trusting they are in good standing are over. You now have a vested interest in your lab’s ownership structure and their relationship with the FCC.
