FCC brings radio modules into the Covered List

Author Hugues Orgitello Last updated 15 August 2026 ~3 min read

News · Regulatory evolution

Adopted on 28 October 2025 and released on 29 October, Order FCC 25-71 clarifies that radio modules, modular transmitters within the meaning of 47 CFR 15.212, do fall under the rules prohibiting authorization of equipment on the Covered List. It goes further: it also bars authorization of any host product that incorporates such a module. The rules have been in force since 26 December 2025.

In short:

A radio module on the Covered List can no longer obtain individual authorization.
Any product, host or device that incorporates such a module is likewise excluded from authorization.
The applicant must attest that the equipment contains no such module.
The FCC gains a procedure to limit already-granted authorizations, short of full revocation.

Why the clarification was needed

The pre-certified module model sits at the heart of radio design: a manufacturer integrates a module that already holds an FCC ID and relies on that authorization rather than running a full campaign. It is efficient, and it creates a blind spot. If the module comes from an entity on the Covered List, a host product could until now be authorized while carrying exactly the element the rules aim to exclude.

The Commission closed this in two moves:

The module itself. Any modular transmitter within the meaning of 47 CFR 15.212 that appears on the Covered List is barred from authorization.
The host product. Authorization is refused to any product, host or device incorporating such a module. The FCC's reasoning is explicit: authorizing such a host would effectively be authorizing the transmitter itself.

The attestation that shifts the burden of proof

The point that touches every application, including those with no Covered List exposure at all, is the declaration duty. Applicants and responsible parties must attest that the equipment for which authorization is sought does not include a Covered List radio module, under 47 CFR 2.911(d)(5)(i).

In practice this shifts the burden of knowledge onto the finished-product manufacturer. Signing an attestation means knowing precisely which module sits on the board, under which part number and from which actual source, which is not always documented when the module arrives through a contract manufacturer or an integrator.

Limiting authorizations already granted

The order's second contribution is procedural. The FCC adopts a prospective limitation mechanism, distinct from outright revocation: the Office of Engineering and Technology and the Public Safety and Homeland Security Bureau can prohibit continued importation and marketing of already-authorized covered equipment, while letting devices already in the field keep operating.

Sections 2.939, 2.803 and 2.1204 of 47 CFR are revised accordingly. The distinction matters to an operator: the installed base is not targeted, continued sales are.

What to do

Document the origin of every radio module fitted in your products, part number and actual manufacturer, before signing an attestation.
Question your assembly subcontractors: a change of module source mid-production can invalidate an earlier attestation.
Review existing authorizations that rest on a third-party module, particularly on long-lifecycle lines.
Expect more, because this order is the first storey: the same logic was later extended to logic-bearing hardware components by FCC 26-50 in July 2026.