The FCC just changed where manufacturers can complete FCC-recognized testing and certification for the U.S. market.
On October 29, 2026, the Federal Communications Commission adopted a Third Report and Order and Third Further Notice of Proposed Rulemaking in ET Docket No. 24-136. The rules limit recognition of Test Labs, Telecommunication Certification Bodies (TCBs), and laboratory accreditation bodies to entities located in the United States or a Reciprocal Economy.
FCC Source: https://www.fcc.gov/document/fcc-proceeds-device-test-lab-onshoring-reciprocity-rules
The FCC defines a Reciprocal Economy as the territory of an economy with which the United States has entered into reciprocal treatment through a Mutual Recognition Agreement or a trade agreement with comparable reciprocal provisions.
Beginning December 1, 2028, equipment authorization applications received on or after that date must rely on required testing and certification activities performed by eligible recognized entities in the United States or a Reciprocal Economy.
The rules also address where substantive “covered activities” may be performed. For Test Labs, these include test setup and operation, required measurements, technical analysis, and preparation or approval of test reports. For TCBs, they include application evaluation, technical review, certification decisions, and FCC-required post-market surveillance.
The question manufacturers should be asking is simple:
What does this mean for my next product launch?
Manufacturers should now consider:
- Is the current Test Lab located in the United States or a Reciprocal Economy?
- Where are the covered activities supporting the FCC application actually performed?
- Which product launches may extend beyond December 1, 2028?
- Is alternative testing and certification capacity already secured?
MiCOM Labs is a U.S.-based ISO/IEC 17025-accredited Test Lab and ISO/IEC 17065-accredited certification body with established FCC capabilities. For more than two decades, we have invested in laboratory infrastructure, engineering expertise, automation, and cloud-based workflows.
Testing and certification capacity is becoming a product-launch consideration, not simply a final compliance step.
Contact MiCOM Labs to review your current testing pathway, identify affected programs, and plan capacity.