The FCC published a Third Further Notice of Proposed Rulemaking in ET Docket No. 21-232 (FCC 26-50; 91 FR 51139) seeking comment on additional security measures for the equipment authorization program. Proposals include bifurcating Covered List rules; addressing white labeling; possible hardware and software bill of materials (HBOM/SBOM) disclosures; broader restrictions on equipment containing Covered List components or software; requiring certification for devices in Covered List sectors; reforming importation, marketing and pre-authorization operation rules; restricting use of the FCC logo; streamlining revocation; considering term limits on equipment authorizations; registering SDoC devices; modernizing the equipment authorization database; and requiring a U.S.-based liable party for FCC-certified equipment. Comments are due September 8, 2026 and reply comments September 21, 2026.
Impact
Impact assessment: High if finalized. The proposal could materially change FCC certification data requirements, supply-chain disclosures, import pathways, SDoC administration, authorization duration, liable-party obligations and post-market enforcement.
Who is affected?
Equipment manufacturers, importers, FCC grantees, U.S. responsible parties, Telecommunications Certification Bodies, laboratories, e-commerce/marketing actors and suppliers in Covered List sectors.
Conclusion:
stakeholders should review FCC 26-50 and consider comments before September 8, 2026.
Regulatory Authority
Federal Communications Commission (FCC)
Regulatory Impact
| Impact Type | Status |
|---|---|
| Top Priority | |
| Type Certificate | |
| Spectrum Bands | |
| Import Changes (HS Codes) | |
| Standard Changes | |
| Product Changes | |
| Label Changes |