ORBIS Compliance

United States FCC Proposes Broad Security and Supply-Chain Changes to the Equipment Authorization Program

Published /Effective /United States of America

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 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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