A testing deadline for an industry built around China
The U.S. Federal Communications Commission has voted to exclude Chinese laboratories from testing electronics for the American market from December 1, 2028, setting a deadline for manufacturers to move work out of a country that handled 82% of such testing in 2025.
Contents
- A testing deadline for an industry built around China
- What the FCC is changing
- Why laboratories have become a security issue
- A false reporting case shows the enforcement stakes
- Where manufacturers can take their testing
- How China became the main testing center
- What moving the work could cost
- The steps leading to December 2028
- A parallel dispute over telephone numbers
- Key Points
The October 29, 2026, decision covers products including smartphones, cameras and computers. It expands restrictions introduced in 2025 that targeted laboratories owned or controlled by the Chinese government. The new approach makes a laboratory's location and its country's reciprocal arrangements with the United States central to eligibility.
FCC Chairman Brendan Carr says fewer than 4% of electronic devices undergo testing in American laboratories. China's 82% share was therefore more than 20 times the U.S. share, showing the scale of the work that manufacturers may need to redirect.
Existing equipment certifications will remain valid, and products already approved will not need fresh testing because of this change. Applications submitted before December 1, 2028, will be processed under the current rules. The immediate task for manufacturers is to plan testing for future products and applications around that cutoff.
The decision follows the December 2028 deadline set out after the FCC vote. Its practical effects extend beyond laboratory owners: companies developing devices in China may have to send prototypes elsewhere, reserve unfamiliar testing facilities and adjust production schedules.
China has condemned the restrictions as an abuse of national security powers. Testing companies have warned that replacing China's capacity will take time, particularly where manufacturers need specialized equipment or expertise.
What the FCC is changing
The FCC oversees an equipment authorization system that checks whether electronic devices meet applicable U.S. requirements before they enter the market. For devices that emit radio waves, testing can include measurements of radio frequency interference, meaning unwanted signals that could disrupt other equipment or communications.
Laboratories carry out technical measurements, while certification bodies review the evidence needed for approval. Both are covered by the new restrictions. For a manufacturer, losing access to an accepted laboratory means finding another eligible facility before completing the relevant authorization process.
The FCC says it will exclude testing and certification bodies in countries that deny equivalent opportunities to laboratories based in the United States. Washington and Beijing have no agreement providing the reciprocal recognition required under the new approach.
A mutual recognition agreement allows participating economies to accept specified testing or certification work performed under each other's systems. Recognition depends on the agreement's scope and the regulator's requirements. It does not mean every product automatically receives approval.
The geographic rule reaches further than the restrictions adopted in 2025. Those measures affected several dozen laboratories with links to the Chinese government, but the FCC says a substantial majority of laboratories in China continued testing electronics for the American market afterward.
Why laboratories have become a security issue
Carr's argument centers on the access laboratories receive during product development. A company seeking approval may share prototypes, designs and technical information well before customers can buy the finished device.
Carr, the FCC chairman, described that access when explaining the decision:
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 says an untrustworthy laboratory could allow unsafe equipment into the market, expose confidential technology or contribute to interference affecting communications networks. Its policy combines those security concerns with a demand for reciprocal commercial access for American laboratories.
For manufacturers, the change adds another requirement to the approval process. They must consider whether a laboratory is technically capable of testing a device and whether its location remains eligible under FCC rules.
A false reporting case shows the enforcement stakes
The FCC has also pursued individual laboratories over the reliability of their work. On June 25, 2026, it moved to withdraw recognition from SLG-CPC Test Laboratory in Dongguan, China, after investigating false testing information.
The agency said the laboratory admitted submitting multiple reports containing data copied from other reports. Investigators identified 33 FCC equipment authorization identifiers supported by identical testing reports prepared by the laboratory.
SLG-CPC attributed the falsified reports to inadequate review procedures among its staff. The FCC described the action as one of 23 laboratory authorization withdrawals under its Bad Labs initiative, which targets laboratories owned or directed by foreign adversaries.
The case illustrates why the accuracy of laboratory records matters. Certification bodies depend on those records to decide whether equipment meets technical requirements. When measurements are copied rather than properly produced, the review process loses the evidence it needs.
Where manufacturers can take their testing
Laboratories in the United States and eligible reciprocal economies remain alternatives. More than 60 economies are described as meeting the reciprocity conditions, with Taiwan, Japan and Vietnam among the locations identified for manufacturers considering other testing arrangements.
The FCC also plans a simpler approval process for devices tested in American laboratories or laboratories in countries it does not regard as national security risks. That gives manufacturers an incentive to move work before the final exclusion takes effect.
Hong Kong's treatment has changed during the policy debate. An April 30, 2026, proposal contemplated including laboratories in both mainland China and Hong Kong and allowing public comments before a final decision. The later October account describes Hong Kong laboratories as retaining eligibility through telecommunications recognition arrangements under the Asia Pacific Economic Cooperation framework.
Hong Kong's position therefore has a specific basis in the recognition arrangements used for telecommunications testing. The central requirement for companies choosing a facility is whether that laboratory's location and authorization qualify under the adopted rules.
Foreign ownership alone does not solve the problem for a laboratory operating in mainland China. The October policy is described as turning on location rather than simply the nationality of the company that owns the facility.
How China became the main testing center
China's role expanded sharply over nearly two decades. In 2007, Chinese laboratories handled about 13% of the relevant electronics testing, compared with about 31% in the United States. By 2025, China's share had reached 82%, while the American share had fallen below 4%.
Those figures show an increase of 69 percentage points for China and a decline of more than 27 percentage points for the United States. They describe a major shift in where manufacturers carry out the checks needed to bring products to the American market.
International testing company Element has explained the commercial reasons for that concentration. Laboratories close to factories reduce shipping costs and allow engineers to move more quickly between building a prototype, checking it and making changes.
Element described the relationship between manufacturing and testing:
for years, global manufacturers have benefited from the scale of China's testing infrastructure, particularly because laboratories are located close to manufacturing facilities, reducing logistics costs and shortening development cycles. Replacing that capacity will not happen overnight.
Earlier figures placed the share of testing conducted in China at about 75%. The FCC's later figure of 82% relates to 2025 and is the figure Carr used to explain the reach of the October decision.
What moving the work could cost
Element warns that shifting testing to other approved laboratories could mean longer waits, higher costs and more difficult scheduling. Manufacturers may also have less access to specialists who handle uncommon types of testing.
A prototype that fails a test often needs changes and another round of measurements. When the laboratory is near the factory, engineers can complete that cycle with fewer shipping and scheduling steps. Moving the laboratory work abroad can add time each time a product needs another check.
Cost estimates associated with the earlier proposal suggested that testing in the United States could cost three to four times as much as testing in China. No industrywide estimate has been given for the total cost of relocation or the resulting effect on retail prices.
Zhou Mi, a senior research fellow at the Chinese Academy of International Trade and Economic Cooperation, warned that companies dependent on Chinese testing would face the expense of adapting to the policy:
It will create direct and significant uncertainty for US product supply chains, while forcing global enterprises that rely on the capabilities of Chinese labs to bear the adjustment costs of these policy shifts,
The transition period gives manufacturers time to find alternatives. Their practical challenge is to secure enough capacity for new devices while preserving access to the particular tests each product requires.
The steps leading to December 2028
The restrictions developed through several decisions rather than a single immediate shutdown. The sequence matters because earlier actions targeted ownership, while the October decision broadens the test to geography and reciprocal recognition.
- May 2025: The FCC considered restrictions on laboratories owned, controlled or directed by entities posing national security risks. Restrictions adopted that year affected several dozen facilities.
- April 30, 2026: The FCC advanced a broader proposal involving laboratories in China and Hong Kong, with a public comment process and a possible transition period.
- June 25, 2026: The FCC acted against SLG-CPC Test Laboratory in Dongguan over false testing information.
- October 29, 2026: The FCC voted for the broader exclusion of laboratories and certification bodies in countries lacking the required reciprocal treatment.
- November 19, 2026: The FCC plans a vote on a separate proposal concerning access to U.S. telephone numbers.
- December 1, 2028: The laboratory restrictions are scheduled to take effect, with applications submitted before that date handled under existing rules.
Manufacturers already holding valid certifications can continue relying on them. Companies preparing later applications will need to build the new laboratory requirements into their development and authorization schedules.
A parallel dispute over telephone numbers
The FCC's planned November 19 vote concerns a different part of the communications system. The proposal would restrict China Mobile, China Telecom, China Unicom and other providers of services using internet protocol from obtaining U.S. telephone numbers directly.
The agency says that measure aims to protect national security and Americans from illegal robocalls. Robocalls use automatic dialing systems or recorded voice messages, and scammers can use them to reach large numbers of potential victims.
The FCC also plans restrictions on service providers using equipment from companies it considers security risks, including Huawei and ZTE. Those steps accompany other actions involving telecommunications connections, drones, consumer routers and devices containing components from restricted companies.
Chinese Foreign Ministry spokesperson Guo Jiakun rejected the laboratory and telephone number measures, accusing Washington of stretching the concept of national security and using state power against Chinese businesses.
Guo said the measures harm normal trade between Chinese and American companies and work against the interests of businesses and consumers. He stated China's response in these terms:
China will do what is necessary to firmly defend its legitimate and lawful rights and interests,
Zhang Xiaorong, director of the Beijing based Cutting-Edge Technology Research Institute, also criticized the laboratory policy as protectionism that politicizes commercial testing. The dispute now combines competing positions on security, market access and the cost of reorganizing electronics production.
Key Points
- The FCC voted on October 29, 2026, to exclude Chinese testing laboratories from its electronics authorization system from December 1, 2028.
- Carr says Chinese laboratories handled 82% of relevant testing in 2025, compared with fewer than 4% in the United States.
- Existing certifications remain valid, and applications submitted before the deadline will use current rules.
- The broader policy centers on laboratory location and reciprocal recognition, expanding earlier restrictions based on government ownership or control.
- Manufacturers face possible increases in testing costs, shipping time and competition for specialized laboratory capacity.
- A separate FCC vote concerning direct access to U.S. telephone numbers is scheduled for November 19, 2026.
- China opposes the measures and says it will act to protect its lawful interests.






