FCC test labs: fast track and new disclosures

Author Hugues Orgitello Last updated 15 August 2026 ~4 min read

News · Regulatory evolution

Adopted on 30 April 2026 and released on 1 May, Order FCC 26-28 rewrites the rules governing certification bodies (TCBs), test laboratories and accreditation bodies. The adopted rules have been in force since 15 June 2026. The consultation that accompanies them goes further: it proposes to stop recognising laboratories established in economies without a reciprocity agreement with the United States.

In short:

A priority processing queue is created for applications tested in a trusted laboratory.
Laboratories and TCBs must report the number and location of staff assigned to FCC-recognised testing and certification.
The control threshold for a prohibited entity stays at 10 %, with reporting from 5 %.
The ban on non-reciprocal laboratories remains a proposal; no decision has been taken.

The Trusted Test Lab fast track

The central mechanism is an incentive, not a prohibition. The FCC creates an accelerated processing queue for applications subject to Pre-Approval Guidance where testing was carried out in a so-called trusted laboratory. That category covers laboratories recognised by the Commission and established:

in the United States,
in an economy bound by a mutual recognition agreement in which the FCC participates,
or in a reciprocal economy under a trade agreement containing conformity assessment reciprocity provisions.

The Office of Engineering and Technology is directed to maintain a separate, streamlined list for those applications. The result is a two-speed system: a fast queue for trusted laboratories, the standard queue for everyone else.

The new disclosure duties

Three reporting obligations are added, applying at initial designation and at biennial renewal alike:

Obligation	Scope
Staffing	Number and location of all employees engaged in FCC-recognised testing and certification, foreign-based staff included. Business addresses suffice; no personal data is requested absent an investigatory need
Ownership	Prohibited-entity control threshold held at 10 % of voting rights or equity, with a reporting duty from 5 %
US listed companies	The trigger becomes actual knowledge, for instance an SEC filing of type 13D or 13G, instead of a 30-day deadline

That last point follows the grant of a reconsideration petition filed by Garmin, which argued it was not practically possible to monitor its own free float continuously.

Post-market surveillance and reporting

The order also directs the Office of Engineering and Technology to take on three work items, with no stated deadline:

Revise the KDB 610077 procedure for post-market surveillance: clarified sampling rates and quotas, escalation paths where cooperation is withheld, public transparency on significant findings.
Open a confidential reporting channel allowing industry participants to report suspected violations or national security concerns.
Publish a consolidated list of prohibited entities, in human-readable and machine-readable form to the extent feasible.

The context: the campaign against failing laboratories

These rules sit inside a clean-up campaign running since 2025. In June 2026 the Office of Engineering and Technology opened a proceeding to withdraw recognition from SLG-CPC Test Laboratory Co., Ltd., based in Dongguan. The laboratory admitted submitting test reports whose data had been copied from one report to another; the investigation identified 33 separate FCC identifiers resting on identical test data. The Commission states that it has denied or withdrawn recognition from 23 laboratories since the campaign began.

The risk to a manufacturer is direct and often underestimated: an authorization resting on falsified data is weakened regardless of the holder's good faith. If one of your FCC identifiers was obtained through a laboratory that has since lost recognition, that grant can be called into question, and customs clearance is not the moment to find out.

What is proposed, and what is not

The attached consultation proposes to stop recognising laboratories, TCBs and accreditation bodies established in non-reciprocal economies, with several possible mechanisms: immediate prohibition, deferred implementation, or gradual phase-out at renewal. Failing a ban, the Commission floats alternatives including a per-application surcharge in the order of 20,000 dollars, longer queues and enhanced surveillance.

One clarification is worth making, because this travels badly: no prohibition and no phase-out period have been adopted. References to a two-year phase-out are commentary on the proposal, not a rule in force. Comments closed on 15 June 2026 and replies on 14 July 2026; the Commission has not yet ruled.

What to do

Inventory the laboratories used for your existing authorizations and identify those established in a non-reciprocal economy.
Verify that none of your FCC identifiers came from a laboratory that has lost recognition.
For new projects, factor the priority queue into laboratory selection: the timing benefit is available now, without waiting for the consultation to conclude.
Plan a migration of the test plan toward a trusted laboratory for long-lifecycle product lines.