USA – FCC NPRM 2026: Restrictions on Foreign Test Labs & Fast-Track for Trusted Labs
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On April 30, 2026, the U.S. Federal Communications Commission (FCC) unanimously adopted a landmark regulatory package - FCC 26-28) combining a Notice of Proposed Rulemaking (NPRM), a Report and Order, and a Second Further Notice of Proposed Rulemaking. The decision reshapes the foundation of the U.S. equipment authorization program by restricting recognition of test labs in non-reciprocal countries and creating a fast-track approval pathway for devices tested in Trusted Test Labs.
This action represents one of the most significant overhauls of the FCC's testing and certification framework in over a decade, directly impacting global manufacturers seeking access to the U.S. market.
Background: Why the FCC NPRM on Foreign Test Labs Matters
Before 2015, the FCC only recognized test labs and certification bodies located in the United States or in countries with a Mutual Recognition Agreement (MRA) with the U.S. After 2015, recognition was expanded to additional foreign laboratories, but recent national security concerns and the FCC's enforcement actions against so-called "Bad Labs" controlled by foreing adversaries have prompted a return to the original. more restrictive model.
Since 2024, the Commission has withdrawn or denied recognition for twenty-three test labs, most notably entities tied to China, including Chongqing Academy (CAIC), TUV Rheinland/CCIC (Ningbo), CVC Testing Technology, and Telecommunication Technology Labs (CAICT).
Key Provisions of the FCC NPRM Foreign Test Labs Rule (FCC 26-28)
1. Prohibition of Non-Reciprocal Foreign Test Labs
The NPRM proposes to prohibit FCC recognition of test labs, Telecommunication Certification Bodies (TCBs), and laboratory accreditation bodies in countries that:
Do not have a Mutual Recognition Agreement (MRA) with the United States, or
Do not have a comparable reciprocal trade agreement in effect.
Affected laboratories would be phased out over a two-year transition period following the adoption of final rules.
2. Fast-Track Priority Review for Trusted Test Labs
The Order establishes a priority "fast-track" PAG (Permit-But-Ask Grant) review process under 47 CFR § 2.964 for applications using Trusted Test Labs, defined as laboratories located in:
The United States, or
A Reciprocal Economy / Territory (a country with an MRA or equivalent trade agreement).
3. New Transparency, Disclosure & Enforcement Measures
The Order also adopts a series of integrity measures:
Mandatory disclosure of foreign employees and testing locations involved in FCC-recognized activities by test labs and TCBs.
A consolidated list of prohibited testing labs to facilitate applicant screening.
Stronger post-market surveillance procedures.
Enhanced enforcement mechanisms.
New confidential reporting channels for industry participants to flag violations or national security threats.
What This Means for Manufacturers
The FCC NPRM foreign test labs rule will have direct operational, financial, and strategic implications for any manufacturer marketing wireless or RF-enabled devices in the U.S.:
Certification strategy must be reassessed. Manufacturers currently using labs in non-reciprocal countries (notably China) will need to migrate testing activities to U.S.-based or MRA-country labs before the phase-out deadline.
Lead times may shift. Devices tested in Trusted Test Labs will benefit from faster FCC approval through the fast-track PAG review, while non-reciprocal pathways disappear entirely.
Supply chain visibility increases. Manufacturers should expect deeper documentation requirements regarding lab personnel, ownership, and testing locations.
Cost implications. U.S. and MRA-country testing typically carries higher fees, which should be factored into 2026–2028 compliance budgets.
IP protection improves. The FCC explicitly cites reduced risk of intellectual property theft as a benefit of using Trusted Test Labs.
Certification Impact Summary
Area | Current Situation | After FCC 26-28 Adoption |
Test labs in non-MRA countries (e.g., China) | Recognized for FCC testing | Phased out within 2 years |
Test labs in the U.S. and MRA countries | Standard processing | Eligible for fast-track PAG review |
TCBs in non-reciprocal economies | Recognized | Recognition revoked |
Foreign staff disclosure | Not required | Mandatory |
Post-market surveillance | Limited | Strengthened |
Whistleblower channels | None | Confidential reporting enabled |
IP protection | Variable | Strengthened through Trusted Labs |
Timeline + Required Actions Regulatory Timeline
Date | Milestone |
April 9, 2026 | FCC Fact Sheet circulated for tentative consideration |
April 30, 2026 | FCC unanimously adopts FCC 26-28 (Order + NPRM + Second FNPRM) |
Pending | Publication in the Federal Register (triggers comment period — typically 30 days for comments, 15 days for reply comments) |
TBD (2026) | Adoption of final rules |
+ 2 years after final rule adoption | Full phase-out of non-reciprocal foreign test labs |
Required Actions for Manufacturers
Audit your current certification supply chain. Identify which test labs and TCBs currently used are located in non-reciprocal economies.
Engage U.S. or MRA-country labs. Begin onboarding alternative labs in Trusted jurisdictions to avoid bottlenecks once the phase-out begins.
Update internal documentation. Prepare to disclose foreign staff and testing locations involved in your equipment authorization activities.
Monitor the Federal Register. Track the comment deadline and reply comment deadline to participate in the rulemaking, if relevant.
Budget for testing migration. Allocate resources for potentially higher testing costs in Trusted Test Labs during 2026–2028.
Reassess product roadmaps. Devices planned for launch in late 2027 or beyond should be tested under the new framework from the outset.
The FCC NPRM foreign test labs initiative is more than a regulatory tweak it is a strategic realignment of the U.S. equipment authorization program around national security, reciprocity, and supply chain integrity. Manufacturers who act early will benefit from faster approvals through the fast-track Trusted Test Lab pathway, while those slow to adapt risk significant disruption during the two-year transition.
For ongoing compliance support, monitor official FCC publications and ensure your certification strategy aligns with the new Trusted Test Lab framework.
