FCC ends recognition of test labs in China and other non-reciprocal economies
From December 1, 2028, new US device approvals must be tested in the US or a reciprocal economy, a rule that moves testing out of China.
The Federal Communications Commission voted at its October 29 open meeting to adopt a Third Report and Order in ET Docket 24-136 that ends FCC recognition of test laboratories, telecommunications certification bodies, and laboratory accreditation bodies located in economies that do not give American test labs reciprocal treatment. From December 1, 2028, equipment authorization applications must rely on testing, certification, and accreditation performed in the United States or a reciprocal economy, defined as an economy with a mutual recognition agreement or a comparable reciprocal arrangement with the United States. Mainland China is not on that list; Hong Kong, Taiwan, Canada, Japan, South Korea, the United Kingdom, and EU member states are.
The scale of the shift is the story. Of 609 FCC-recognized test labs, about 25 percent are in mainland China, and Chinese labs tested 82 percent of devices that applied for FCC authorization in 2025, against fewer than 4 percent tested in American labs. The rule does not revoke existing equipment grants or require retesting of devices already authorized, and applications received before December 1, 2028 continue under the current rules. The draft order provided no waiver process or case-by-case exceptions for labs in non-reciprocal economies, so manufacturers should not expect individual relief from the cutoff. The FCC had not posted the final order text at the time of writing, so the transition terms here follow the draft order as adopted.
The order is the second rung of a ladder the FCC started building in May 2025, when its Bad Labs rules barred recognition of any lab, certification body, or accreditation body owned, controlled, or directed by entities linked to foreign adversary governments, regardless of where the lab sits. Dozens of labs have lost recognition under that ownership test since. The October order adds a location test on top of it: a lab in a non-reciprocal economy loses recognition even if it has no link to an adversary government. The ban moves from who owns the lab to where the lab sits.
For robotics, the rule bites on market access, not on product origin. Every radio device sold in the United States, including humanoids, quadrupeds, and home robots with Wi-Fi, Bluetooth, or cellular radios, needs FCC equipment authorization before import. A Chinese robot maker can still win a grant after December 2028 if it moves testing to a lab in the United States or a reciprocal economy such as Taiwan, Japan, or South Korea. What it cannot do is keep testing in mainland China. The boundary case proves the point: foreign-made drones and critical components added to the FCC Covered List in December 2025 cannot get new grants at all, no matter where they are tested. At the same meeting, the FCC separately voted 3-0 to open the 800 MHz cellular band to drones, easing spectrum access even as the testing door narrows.
What to watch next is capacity, not just compliance. If most of the world's device testing must move out of China within about two years, reciprocal-economy labs become the bottleneck, and the FCC's Office of Engineering and Technology is directed to publish implementation guidance and maintain the reciprocal-economy list. A companion proposal also seeks comment on a possible third step: extending the ban to entities owned or controlled by a non-reciprocal economy, which would close the route of reincorporating elsewhere while keeping the work in place.