FCC Test Lab Reciprocity Rules Adopted: 2028 Cutoff Set
FCC Test Lab Reciprocity Rules Adopted: Testing Must Move to the US or Reciprocal Economies by December 2028
The FCC test lab reciprocity rules are no longer a proposal. On 29 October 2026, the Federal Communications Commission adopted a Third Report and Order and Third Further Notice of Proposed Rulemaking (FCC 26-73) in ET Docket No. 24-136. Chairman Carr and Commissioners Gomez and Trusty all voted in favour. The order limits the FCC's recognition of test labs to those located in the United States or in countries that give US labs reciprocal recognition, and it sets 1 December 2028 as the date from which all testing, certifying and accreditation work must happen there.
Background: from "bad labs" to reciprocity
Almost every RF device sold in the US needs FCC equipment authorization, and that depends on testing at an FCC-recognized lab and, for certification, review by a Telecommunication Certification Body (TCB). Last year the FCC barred labs owned or controlled by foreign adversaries or other entities deemed national security threats. According to the FCC, 29 labs have since lost their recognition over those ties, and two more labs in non-Reciprocal Economies had recognition withdrawn for copying test results.
The next step was reciprocity. The FCC says fewer than 4% of electronic devices are now tested in US labs, with most testing done in countries that don't recognize US labs in return. Chairman Carr's statement puts China's share at 82.3%. The draft order was released on 8 October 2026, and GMA Labs covered it on 22 October ahead of the vote.
Key Changes in the FCC Test Lab Reciprocity Rules
The FCC's news release and fact sheet set out three main changes.
Recognition limited to the US and Reciprocal Economies
The FCC will recognize test labs, TCBs and laboratory accreditation bodies only where they're located in the United States or in a Reciprocal Economy. The fact sheet defines a Reciprocal Economy as a country or territory that has a Mutual Recognition Agreement (MRA) or a comparable reciprocal agreement with the US.
Location of the work counts too
The restriction isn't only about where a lab is headquartered. Labs, TCBs and accreditation bodies based in the US or a Reciprocal Economy also fall under it if they carry out the testing, certifying or accrediting activities in a non-Reciprocal Economy.
One transition date: 1 December 2028
Labs in non-Reciprocal Economies stay recognized during the transition, and OET can keep granting recognitions until then. All of those recognitions end automatically on 1 December 2028, whenever they were issued.
Further Notice
The Commission is also asking for comment on ways to expand testing capacity in the US and Reciprocal Economies, and on further integrity measures. These include Legal Entity Identifiers for labs, TCBs and accreditation bodies, better post-market surveillance, requiring Supplier's Declaration of Conformity (SDoC) testing to be done in FCC-recognized labs, and a modernized FCC database. Comments will be due 30 days after Federal Register publication.
What This Means for Manufacturers
Any product that needs FCC certification after 1 December 2028 will have to be tested in the US or a Reciprocal Economy. Test reports from labs elsewhere won't support new applications from that date.
Capacity is the real constraint. If most FCC testing is currently done in non-reciprocal countries, labs in the US and Reciprocal Economies are likely to get busier as 2028 approaches.
Product roadmaps matter. Launches planned for late 2028 and beyond should be matched with a qualifying lab now, not in the final months.
Multi-market test plans may need rework. Many manufacturers use one lab for FCC, ISED and other approvals, and that pattern may have to change for the US part.
SDoC products are worth watching. The Further Notice could bring them into the same framework.
Final details depend on the released order. Points such as the Reciprocal Economy list and the treatment of existing grants should be checked against the official text once it's published.
Certification Impact Summary
Area | Before | After | Impact level |
Where FCC test labs can be recognized | Any country, subject to accreditation and the 2025 "bad labs" ban | US or a Reciprocal Economy only | High |
TCBs and accreditation bodies | No location limit | Same US or Reciprocal Economy limit | Medium |
Labs in Reciprocal Economies working elsewhere | Allowed | Covered work must be done in the US or a Reciprocal Economy | High |
Recognitions in non-Reciprocal Economies | Ongoing | Continue during transition, end automatically 1 December 2028 | High |
SDoC testing | No requirement to use a recognized lab | Under consultation in the Further Notice | Medium |
Existing FCC grants | Valid | To be confirmed in the released order | Low |
Timeline and Required Actions
Key Dates
Date | Milestone |
8 October 2026 | Draft order and fact sheet released |
29 October 2026 | FCC adopts FCC 26-73 by a 3–0 vote |
To be confirmed | Full text released and published in the Federal Register; Further Notice comments due 30 days later |
1 December 2028 | Transition ends; testing, certifying and accreditation must take place in the US or a Reciprocal Economy |
Required Actions for Manufacturers
List every product that will need FCC certification from late 2028, with planned launch dates.
Find out where each one is tested today, including where the measurements and report approvals actually happen.
Check whether those locations are in the US or a Reciprocal Economy once the FCC publishes its list.
Book capacity with a qualifying lab early for launches close to or after 1 December 2028.
Review SDoC products in case the Further Notice brings them into scope.
Consider filing comments on the Further Notice once the comment date is set.
Conclusion
With FCC 26-73 adopted, the FCC test lab reciprocity rules give manufacturers a fixed date: from 1 December 2028, FCC testing and certification work has to happen in the US or a Reciprocal Economy. Two years sounds like plenty, but lab capacity and product cycles make it tighter than it looks. Contact our team for help mapping your current testing and planning US approvals around the new rules.
