FCC Adopts Rules Limiting Recognized Device Test Labs to the U.S. and Reciprocating Countries

The U.S. Federal Communications Commission has adopted rules that will limit its recognition of device test labs to those located in the United States or in countries that grant U.S. labs reciprocal recognition. The action was announced October 29, 2026.

Every electronic device must be tested at an FCC-recognized lab before it can be marketed or used in the U.S. The FCC says the change is meant to ensure fair and reciprocal treatment for U.S. industries.

The geographic requirement adds to restrictions the FCC has already put in place:

• May 2025: ownership restrictions on test labs adopted.
• September 2025: foreign-adversary ownership rules took effect.
• April 2026: priority review adopted for devices tested in trusted labs, and the reciprocity rulemaking launched.
• June 2026: trusted-lab fast-track rules took effect.

The location rule matters because testing is concentrated overseas. Of 591 FCC-recognized labs, 126 (about 21%) are in China and Hong Kong. The FCC reports that fewer than 4% of electronic devices are tested in U.S. labs. Estimates of the share tested in China-based labs range from 75% to 82%, depending on the source and method.

Manufacturers selling radio-equipped products in the U.S. are most exposed, including makers of phones, laptops, networking gear, smart home devices, vehicle telematics and connected medical devices. So are ODMs, EMS providers and module vendors that choose test facilities on a brand’s behalf. Compliance advisers note that a lab owned by a Western company can still sit in a non-qualifying location, so both location and ownership will matter. They also warn that demand shifting to eligible labs could lengthen queues for specialist testing, and that testing farther from the factory adds shipping and retest time.

Transition provisions for existing equipment grants, product modifications and retesting are set out in the order itself, which this summary does not cover.