A Testing Rule With a Large Reach
The U.S. Federal Communications Commission voted on October 29 to exclude laboratories and certification bodies in China from approving electronic products for the American market, with the restrictions scheduled to take effect on December 1, 2028. The decision targets a testing network that FCC Chairman Brendan Carr said handled 82% of electronic devices authorized for sale in the United States in 2025.
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The rule reaches beyond China. It bars testing and certification bodies in countries that lack the required mutual recognition or reciprocal arrangements with the United States. Because Washington and Beijing have no such agreement, laboratories located in China would lose access to this work regardless of who owns them.
Smartphones, computers and cameras are among the products affected. Manufacturers that use Chinese laboratories will need to arrange testing in the United States or an eligible foreign economy before the deadline. For companies producing devices in China, that could separate a familiar part of product development from the factories making the equipment.
Carr put the American share of testing at less than 4%, compared with China's 82%. Using those figures, China's share was more than 20 times the U.S. share. That imbalance explains why a rule about laboratory eligibility could become a substantial challenge for manufacturers, testing companies and regulators.
What Recognition Agreements Do
A mutual recognition agreement, commonly called an MRA, allows countries to accept specified testing or certification work performed under each other's systems. In practical terms, it can let a manufacturer have equipment checked in one country for acceptance in another, subject to the agreement's scope and the regulator's requirements.
The FCC's decision makes reciprocal access central to eligibility. Foreign testing bodies must operate in places that give U.S. laboratories equivalent opportunities. Carr linked the change to President Donald Trump's policy of reshaping America's trade relationships with other countries.
Carr, the FCC chairman, described the planned geographic requirement in a public statement:
Starting 2 years from now, we will only allow for Test Labs to be based in the U.S or "Reciprocal Economies," i.e. those places that are willing to recognize U.S.-based testing,
For manufacturers, the practical question becomes where a laboratory operates and whether that location meets the FCC's rules. A laboratory's technical ability alone would no longer be enough to preserve its eligibility if it is based in an excluded country.
Why the FCC Sees a Security Risk
Carr's security argument centers on the access laboratories receive before products go on sale. Testing can give outside organizations access to confidential designs and technical information months before customers see a device. The FCC considers that access sensitive because the equipment may eventually connect to American communications networks.
Carr explained the role of testing organizations and the information they can obtain:
These labs are a critical gateway into American communications infrastructure -- and their privileged role gives them access to sensitive and confidential information about electronic products often months before the devices enter the market,
The FCC chairman also warned that laboratories could:
allow insecure gear into the US market, disrupt communications networks, or even steal intellectual property.
The agency is therefore treating the testing process itself as part of communications security. Its concern extends from the devices entering the country to the organizations trusted to examine them beforehand. The Chinese Embassy in Washington did not immediately respond to a request for comment on the decision.
From Government Ownership to Location
The FCC had already restricted laboratories owned or controlled by the Chinese government in 2025. It revoked recognition from 32 laboratories that year. Those measures focused on the relationship between particular testing organizations and the Chinese state.
The new rule uses a broader geographic test. A laboratory located in China would be excluded because China lacks the required agreement with the United States, even if the laboratory is privately owned or belongs to a company headquartered elsewhere.
That changes the choices available to laboratory operators. A change in ownership would leave the location problem unresolved. To keep serving the American market, an operator could need testing capacity in an eligible economy, along with the necessary recognition to perform the work there.
The main dates are:
- 2025: The FCC barred laboratories owned or controlled by the Chinese government and revoked recognition from 32 laboratories.
- October 29: The commission voted to extend restrictions to laboratories and certification bodies in countries without the required reciprocal arrangements.
- December 1, 2028: The broader restrictions are scheduled to take effect.
The transition gives laboratories and manufacturers time to change their arrangements. Industry groups are concerned about whether enough eligible capacity will be ready when the deadline arrives.
Why Testing Is Concentrated in China
China has an estimated 170 to 200 laboratories authorized for FCC work. Their concentration reflects the country's role as a major electronics manufacturing center: many devices are tested close to the factories and engineering teams that develop and produce them.
Nearby testing makes it easier to move a device between the factory and the laboratory when engineers need to investigate a problem or submit a revised version. Shifting that work abroad adds another location to the development process and requires manufacturers to coordinate testing schedules across borders.
The cost difference could also matter. Estimates put basic FCC certification testing in China at about $400 to $1,300, compared with $3,000 to $4,000 in the United States. These are estimates for basic testing, and the actual bill depends on the product and the work required.
Even the lower end of the stated U.S. range, $3,000, is more than twice the upper end of the Chinese range, $1,300. Manufacturers moving work to American laboratories could therefore face a substantial increase in this part of their development costs.
Companies can also seek eligible laboratories outside the United States. The rule creates a need to find acceptable testing locations, rather than a requirement that every affected device be tested on American soil.
Can Other Laboratories Absorb the Work?
The Consumer Technology Association and the Telecommunications Industry Association warned the FCC that the change could produce testing shortages and certification backlogs. They called for temporary exemptions and simpler approval procedures to help manage the transition.
Their concern follows directly from the current distribution of testing. With China handling 82% of the devices in Carr's figures and U.S. laboratories handling less than 4%, a large share of existing work would need a new home. Eligible laboratories elsewhere would share that demand with American facilities.
Testing capacity requires suitable equipment, trained staff and authorization to perform the relevant work. An available appointment for one kind of device may not meet the needs of a manufacturer seeking different tests. Companies will need to check both a laboratory's eligibility and its ability to handle their products.
The FCC is also simplifying approval procedures for devices tested in U.S. laboratories or laboratories in countries considered not to pose national security risks. That could reduce administrative delays, while investment in equipment and staffing would address the separate problem of how much testing those facilities can perform.
No detailed allocation of replacement capacity or decision on the industry groups' requested temporary exemptions was specified. For manufacturers, the immediate task is to identify alternative facilities early enough to protect planned product launches.
Why the Decision Matters Beyond China
India is another country manufacturers may need to examine closely. It is absent from the published list of U.S. telecommunications MRA partners, making its position relevant to a rule framed around reciprocal recognition rather than China alone.
A manufacturer moving production or testing from China to India would therefore need to check whether the proposed laboratory satisfies the new requirements. Moving equipment across a border does not automatically provide an eligible route to FCC authorization.
The wider consequence is a new geography for testing work tied to American market access. Economies with qualifying arrangements may become more attractive places for laboratories to expand, while those without them face pressure to address reciprocal access.
For Asian electronics businesses, factory location, laboratory location and destination market will need to be considered together. A device made in one country may need to travel to another for testing before it can enter the United States.
Part of a Broader Technology Clampdown
The laboratory decision joins a series of FCC restrictions affecting Chinese technology. The agency has barred imports of new models of Chinese drones and Chinese consumer routers, the devices that connect phones, computers and other equipment to the internet.
The FCC has also moved against devices containing key hardware from Chinese companies designated as national security risks. Huawei and ZTE are among the companies on the agency's list of firms whose equipment faces restrictions on sale in the United States. Other recent actions have addressed additional equipment from Chinese manufacturers, while proposed restrictions have covered most drones built for military use.
The testing rule reaches a different stage of the same supply chain. Restrictions on particular products determine what equipment can enter the market. Restrictions on laboratories determine which organizations can perform work needed for market approval, including for products made by companies outside China.
Consumers could encounter the effects through changes in launch schedules or manufacturer costs if testing becomes harder to arrange. The concrete deadline is December 1, 2028. Before then, laboratories need eligible capacity and manufacturers need testing plans that will still work when the geographic restrictions begin.
Key Points
- The FCC voted on October 29 to exclude testing and certification bodies in countries without the required reciprocal arrangements with the United States.
- Chinese laboratories would be excluded from December 1, 2028, because China has no qualifying agreement with Washington.
- Carr said China handled 82% of testing for electronic devices authorized for the U.S. market in 2025, compared with less than 4% inside the United States.
- The policy expands beyond the 2025 restrictions on laboratories owned or controlled by the Chinese government.
- Industry groups warned of testing shortages and backlogs, while the FCC is simplifying approval procedures for eligible testing routes.
- Manufacturers considering alternatives, including India, will need to verify that their chosen laboratories meet the new requirements.
