FCC Test Lab Restrictions 2026: New Strategy for Global Compliance

FCC Proposes New Restrictions on Test Labs: What It Means for Your Certification Strategy

On 30 April 2026, the U.S. Federal Communications Commission (FCC) voted to move forward with new rules that could significantly reshape how electronic and wireless products are tested and certified for the U.S. market.

While the proposal is not yet finalized, it signals a material shift in global compliance strategy, particularly for companies relying on international test lab networks.

In this article, I explain what’s changing, what’s still uncertain, and how manufacturers should respond now.

What has the FCC proposed?

The FCC has proposed ceasing recognition of test labs, TCBs and laboratory accreditation bodies located in territories that are not covered by a Mutual Recognition Agreement (MRA) or comparable reciprocal trade agreement with the United States. While some non-MRA countries currently have FCC-recognized accreditation routes, the proposal could change that position if adopted. In practical terms, the near-term industry focus is likely to be on China and Hong Kong, given existing FCC national security scrutiny and recent actions involving test labs linked to foreign adversary concerns.

The proposal includes several key measures:

• Restrict the use of test labs located in countries without a Mutual Recognition Agreement (MRA) or similar reciprocal arrangement with the United States
• Phase out acceptance of test data from these labs over a proposed two-year transition period
• Introduce greater oversight of Telecommunications Certification Bodies (TCBs), including tracking the geographic location of certification personnel
• Consider fast-tracking approvals under the Pre-Approval Guidance (PAG) process when testing is performed in US-based test labs, or test labs in a country with an MRA or reciprocal trade agreement with the USA  (Note*)Strengthen market surveillance and enforcement activities

It appears that the FCC’s proposal will cover equipment tested for certification, such as radio transmitter equipment.  The FCC has not yet clarified if it will also apply to electronic equipment tested for Supplier’s Declaration of Conformity (SDoC).

In parallel, the FCC has begun banning equipment from “entities on the U.S. Covered List (such as specific foreign manufacturers like DJI, Huawei, or ZTE), although some manufacturers have received conditional approvals.

(Note*:  The PAG process applies to complex projects or complex products, where the TCB is required to involve the FCC in the review process before the TCB completes the certification).

A return to (and expansion of) earlier FCC test lab rules

For many in the industry, this proposal reflects a return to pre-2015 requirements, when FCC testing for SDoC was limited to the U.S. or MRA partner countries.

However, this is not simply a reversal.

The proposed rules go further by:

• Potentially applying restrictions more broadly across approval pathways
• Increasing scrutiny on who performs the certification, not just where testing occurs
• Embedding compliance more deeply into national security and supply chain considerations

Key dates for the new FCC testing changes

Several test labs in China have already been prohibited from any FCC testing, for Certification or SDoC, since 8 September 2025 and that prohibition remains in place.

The FCC has already initiated the requirement for TCB companies to report on the location of their reviewing staff, and they have decided on the fast-track PAG process.  These items officially went into effect on 15 June 2026.  In the case of the PAG process, it is expected that there will be two separate PAG lists; one for manufacturers using labs based in the USA or MRA countries, and one for manufacturers using labs based in non-MRA countries.

For the additional topics voted on 30 April 2026, relating to banning testing in countries that lack reciprocity or pose national security risks, specifically China and Hong Kong, the timeline is not yet known.  It is expected that the rules may be published sometime in 2026 and would apply with a two-year transition period.

What this means for manufacturers

While the final rules and timelines are still pending, the direction of travel is clear, and the operational impact could be significant.

Test data risk: Test reports generated in affected geographies may no longer be accepted once the new requirements apply, creating potential rework, retesting or the need for supplemental data.

Certification delays: Moving projects to compliant labs could extend approval timelines, particularly if demand increases quickly in the U.S. and other reciprocal economies.

Increased costs: Manufacturers may face duplicate testing, project transition costs, added logistics and scheduling constraints, especially for products already in the certification pipeline.

Supply chain disruption: Certification dependencies can directly affect product launch schedules, market entry timelines and revenue forecasts, particularly where U.S. approval is tied to global release planning.

Strategic reconfiguration: Global compliance models may need to shift toward regionally resilient testing strategies, with greater reliance on U.S. and reciprocal-economy lab capacity.

Immediate risks and how to avoid production delays

Although the new proposed rules from the April 2026 vote are not yet finalized, there are two areas of genuine urgency. According to TÜV SÜD’s global regulatory team, the highest-risk areas are active certification projects and future capacity constraints:

1. Active and in-flight projects

Projects currently using labs in potentially affected regions are not yet subject to changes which may take place in the future.  However, for products not yet certified, the project may face:

• Changes or delays to the PAG process, if applicable
• Acceptance risk at certification stage, if certification takes place after changes apply
• Possible need for retesting or data supplementation, if certification takes place after changes apply

2. Capacity constraints in compliant labs

Since 8 September 2025, testing capability in China has been reduced, if the new proposed rules are enforced, this is expected to lead to rapid increases in demand for:

• U.S.-based labs
• MRA-country labs

This could result in:

• Longer booking lead times
• Resource congestion

By acting early, your organization will be better positioned to secure capacity and avoid delays.

What’s still unclear

The FCC has not yet published the formal Report and Order, which will define:

• The final list of affected countries
• Implementation timelines
• Transition provisions and grandfathering rules
• Whether the changes will only affect certification testing, or SDoC testing too
• The exact scope of TCB oversight changes

This means manufacturers must plan in an environment where the strategic direction is known, but the operational details are still evolving.

Next steps: How to turn disruption into continuity

To mitigate risk and maintain speed to market, we recommend you review all active and upcoming FCC certification projects. Priority should be given to projects that rely on China or Hong Kong labs, use labs in jurisdictions that may lack reciprocity with the U.S., or involve complex products that may require PAG review.

Short-term planning should focus on evaluating alternative testing locations, engaging early to secure lab capacity and assessing whether PAG-related projects could benefit from U.S. or reciprocal-economy testing. This is also the right time to confirm whether existing test plans, reports and certification pathways remain viable under the FCC’s evolving approach.

From a strategic perspective, manufacturers should reassess their global compliance model and build redundancy into testing programs. TÜV SÜD supports this process through FCC-listed laboratories across North America, Europe and Asia, with integrated RF, EMC and certification services designed to help manufacturers transition projects efficiently and align U.S. FCC requirements with wider global market access needs.

The FCC initiative reflects a broader trend toward increased regulatory scrutiny, tighter geographic control over compliance activities and closer alignment between market access and national policy priorities.

As a manufacturer, your success will depend on the ability to adapt quickly, plan proactively, and execute globally.

Need support dealing with these new FCC test lab rules?

If you’re evaluating how these developments impact your products, timelines, or certification strategy, TÜV SÜD’s global market access team can help you:

• Understand your risk exposure
• Identify compliant test pathways
• Transition projects without disruption
• Provide a global solution for the future

Get in touch with our team to discuss your FCC compliance strategy.