FCC Reciprocal Economy Test Labs: 62 Economies Listed
FCC Reciprocal Economy Test Labs: FCC 26-73 Lists 62 Economies and Keeps Existing Grants Valid
The FCC Reciprocal Economy test labs rules now have their full text. The Federal Communications Commission released FCC 26-73, its Third Report and Order and Third Further Notice of Proposed Rulemaking in ET Docket No. 24-136, on 30 October 2026, a day after the vote. GMA Labs covered the adoption on 30 October from the FCC's news release. The full order answers the questions that were still open: which countries qualify, what happens to existing grants, and what exactly has to be done where.
Background
FCC equipment authorization depends on private test labs, Telecommunication Certification Bodies (TCBs) and the accreditation bodies that assess the labs. The FCC currently recognizes 609 test labs. According to the order, 25.1% of them are in mainland China, 18.4% in Taiwan and 17.9% in the United States. The share of FCC application testing done in China rose from about 13% in 2007 to more than 82% in 2025, while the US share fell below 4%.
The order limits recognition to labs in the US and in Reciprocal Economies, meaning economies with a Mutual Recognition Agreement (MRA) or a comparable reciprocity agreement with the US, such as a free trade agreement or an Agreement on Reciprocal Trade. The cutoff is 1 December 2028.
Key Changes in the FCC Reciprocal Economy Test Labs Rules
62 economies on the list
Appendix D lists 62 Reciprocal Economies. They include all 27 EU member states, the UK, Norway, Iceland and Liechtenstein; Canada, Mexico and twelve other Latin American countries (Argentina, Chile, Colombia, Costa Rica, the Dominican Republic, Ecuador, El Salvador, Guatemala, Honduras, Nicaragua, Panama and Peru); Japan, South Korea, Taiwan, Hong Kong, Singapore, Malaysia, Indonesia, Vietnam, Cambodia, Bangladesh, Australia and New Zealand; and Israel, Bahrain, Oman, Jordan and Morocco. Mainland China, India, Switzerland, Thailand, the Philippines, Brazil, Turkey and Saudi Arabia aren't on it. OET will publish the list on its website, review it regularly, and can add or remove economies.
Existing grants stay valid
This was the biggest open question. The order says equipment authorizations granted, and applications received, before 1 December 2028 aren't affected. Properly certified equipment can still be imported, marketed, sold, operated and modified without retesting just because its lab lost recognition. The FCC can still require retesting for other reasons, such as inaccurate test data.
"Covered activity" is defined
A lab in the US or a Reciprocal Economy can't keep its recognition if it does the FCC work somewhere else. For test labs, covered activity means test setup and operation, the required measurements, technical analysis and preparing or approving the test report used for certification. Pre-compliance and R&D testing that isn't presented as FCC-recognized testing, equipment calibration and back-office work aren't covered. A lab can also keep testing for other countries' approvals in a non-Reciprocal Economy without losing FCC recognition.
A shortened runway for labs outside the list
Labs in non-Reciprocal Economies can keep FCC-recognized activity until the transition date. From 1 December 2026, any new recognition they receive will be shortened so it ends by then, and the rule text sets 30 November 2028 as the last day they're eligible. The FCC won't create a special waiver process.
The Further Notice
The FCC asks whether test labs, TCBs and accreditation bodies should have a Legal Entity Identifier (LEI), and whether to bar entities owned or controlled from non-Reciprocal Economies (it didn't adopt that ban now). It also asks whether equipment authorized under the Supplier's Declaration of Conformity (SDoC) should be tested in labs based in the US or Reciprocal Economies. That's a question, not a rule yet, but it would reach products that never go through a TCB.
What This Means for Manufacturers
The list makes planning concrete. If your FCC testing happens in mainland China, India or another economy that isn't listed, new applications received from 1 December 2028 will need test reports from somewhere else. Labs in Taiwan, South Korea, Japan, Vietnam, Malaysia and Mexico all remain eligible, which gives more options than a US only reading would suggest.
The grandfathering clause is good news for products already on the market. You won't need to retest certified products just because their original lab is outside the list, though it's worth checking how a later change that needs a new application would be handled. OET is due to publish implementation guidance before the transition date.
The FCC expects higher testing costs: about $23.6 million in one-time familiarization costs and about $79.3 million a year in extra testing costs across the industry once the transition ends.
Certification Impact Summary
Area | Before | After | Impact level |
Where test labs can be recognized | Any country, subject to accreditation and the prohibited-entity rules | US or one of 62 Reciprocal Economies for applications received from 1 December 2028 | High |
Where the work is done | No rule | Setup, measurements, analysis and report approval must happen in the US or a Reciprocal Economy | High |
Existing FCC grants | Valid | Still valid; equipment can be sold and modified without retesting solely because of the lab's status | Low |
New recognitions for labs outside the list | Usual two-year term | Shortened so none runs past 30 November 2028 | Medium |
TCBs and accreditation bodies | Already in the US or MRA economies in practice | Location limit written into the rules | Low |
SDoC testing | Any competent lab | Under consultation: labs in the US or a Reciprocal Economy | Medium |
Timeline and Required Actions
Key Dates
Date | Milestone |
29 October 2026 | FCC adopts FCC 26-73 |
30 October 2026 | Full text released with the list of 62 Reciprocal Economies |
1 December 2026 | New recognitions for labs outside the list start being shortened to end by the transition date |
To be confirmed | Federal Register publication; Further Notice comments 30 days later, replies 60 days later; rules take effect 60 days later |
30 November 2028 | Last day labs in non-Reciprocal Economies can be FCC-recognized |
1 December 2028 | Applications received from this date must rely on testing and certification done in the US or a Reciprocal Economy |
Required Actions
Check where each product's FCC testing is actually done, including measurements and report approval, against the 62 economies in Appendix D.
For products planned for late 2028 or later, qualify a lab in the US or a listed economy now.
Keep existing grants and test reports on file; they stay valid, but you'll want them if a modification is needed.
Review your SDoC products and consider commenting on the Further Notice once the deadline is published.
Watch for OET's implementation guidance and the Federal Register effective date.
Conclusion
The released text of FCC 26-73 turns the FCC Reciprocal Economy test labs rules into something manufacturers can plan around: a list of 62 economies, a clear statement that existing grants stay valid, and a defined set of activities that have to stay inside those economies. The open item is SDoC testing, which the FCC is still consulting on. If you'd like help mapping your current labs against the list or planning US approvals for 2028 and beyond, contact our team at contact@gmalabs.com.
