ORBIS Compliance

FCC Proposes to Cease Recognition of Test Labs, TCBs, and Accreditation Bodies in Non-MRA Countries; Seeks Comments on Data Modernization and IP Protection

Published /United States of America

The Federal Communications Commission (FCC) has issued a Second Further Notice of Proposed Rulemaking seeking public comment on a proposal to cease recognition of test laboratories, Telecommunications Certification Bodies (TCBs), and laboratory accreditation bodies located in countries that do not have a Mutual Recognition Agreement (MRA) or reciprocal trade agreement with the United States. This move is intended to enhance the integrity and security of the FCC's equipment authorization program, address national security concerns, and protect intellectual property.

The proposal would prohibit recognition of such entities in non-reciprocal economies and withdraw recognition from those already recognized. The FCC is also considering whether to extend this prohibition to entities owned or controlled by non-reciprocal economies. Alternatives under consideration include imposing a significant fee (e.g., $20,000) for equipment tested in non-MRA countries, implementing stricter post-market controls, or phasing out recognition over a transition period.

Additionally, the FCC is seeking input on modernizing its data analytics capabilities and the Equipment Authorization System (EAS) database to improve enforcement and reduce administrative burdens. The Commission is also requesting feedback on measures to better protect intellectual property during the equipment authorization process, including contractual, technical, and procedural safeguards.

The public comment period for this proposal ends on June 15, 2026, with reply comments due by July 14, 2026. Stakeholders, especially those relying on non-MRA country labs or certification bodies, are encouraged to review the proposed changes and submit their input.

This proposal is assessed as Medium Impact because it is not yet a final rule but, if adopted, would significantly affect the recognition of test labs, TCBs, and accreditation bodies in non-MRA countries, with broad implications for manufacturers, importers, and certification stakeholders.

Key reasons for Medium Impact:

  • The measure is currently a proposal open for public comment, not yet mandatory.
  • If implemented, it would restrict the use of non-MRA country labs and TCBs for FCC equipment authorization, potentially increasing costs and requiring operational changes.
  • The proposal includes possible high fees, transition periods, and stricter post-market controls.

Who is affected?

  • Manufacturers, importers, and certification bodies relying on non-MRA country labs or TCBs.
  • International test labs and accreditation bodies.
  • U.S. and reciprocal economy-based testing and certification providers.

Conclusion

Stakeholders should closely monitor this proceeding and consider submitting comments, as the final rule could have substantial compliance and operational impacts.

Regulatory Authority

Federal Communications Commission (FCC)

Regulatory Impact

Impact TypeStatus
Top Priority
Type Certificate
Spectrum Bands
Import Changes (HS Codes)
Standard Changes
Product Changes
Label Changes

United States of America Quick Facts

Regulatory AgencyFederal Communications Commission (FCC)
Certification TypeMandatory for most telecom equipment
License ValidityValid indefinitely as long as compliance is maintained
Application LanguageEnglish
Legal License HolderLocal representative may be required for some cases
In-country Testing RequirementMay be required for certain telecom equipment

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