A smartphone, wireless camera or laptop does not enter the U.S. market on a manufacturer’s word alone. Radio-frequency devices must pass an equipment-authorization process that checks whether they meet federal technical rules before they are marketed or imported.
On October 7, Federal Communications Commission Chairman Brendan Carr proposed new test-lab onshoring and reciprocity rules. The Commission is scheduled to vote on October 29. If adopted, the rules would generally limit recognition to laboratories and certification bodies in the United States or in countries that recognize U.S. facilities on reciprocal terms. The restrictions are slated to take effect on December 1, 2028.
The proposal has been summarized as a ban on Chinese laboratories, and China would be directly affected. But that shorthand misses the policy’s larger design. This is an attempt to turn reciprocity into a condition of access to the American electronics market while rebuilding more of the testing system at home.
The Laboratory Behind the Approval
The FCC’s equipment-authorization system is one of the agency’s principal tools for ensuring that radio-frequency devices operate without causing harmful interference and comply with its rules. Tests can cover emissions, spectrum use and, depending on the product, exposure and other technical requirements. Certification bodies then review the evidence for devices that require certification.
That work is geographically concentrated. Reuters reported that 82 percent of electronics were tested in China in 2025, while less than 4 percent were tested in U.S. laboratories. Those figures reveal a little-seen supply chain behind familiar devices: compliance testing has become as globally distributed as design, assembly and component manufacturing.
A digital oscilloscope in use on an electronics workbench. Photo: Radarvector/Wikimedia Commons. CC BY-SA 4.0.
An accredited laboratory is not a government guarantee that every product is flawless. The FCC’s own test-firm guidance says manufacturers remain responsible for selecting a facility capable of measuring their device. The system therefore depends on several layers of trust: accreditation, standardized measurement procedures, accurate reports and regulators able to investigate failures.
Reciprocity Becomes a Market Gate
The FCC already tightened that chain in 2025. Its foreign-adversary laboratory order excluded facilities owned, controlled or directed by governments designated as foreign adversaries. The new proposal goes further. A laboratory could be privately owned and technically capable, yet still lose recognition if its home country does not provide reciprocal access to U.S. facilities.
That makes reciprocity more than a diplomatic principle. It becomes part of the device-approval workflow. A manufacturer’s choice of testing location would determine whether its compliance evidence can travel with the product into the U.S. market.
The policy also combines two different ambitions. One is defensive: reduce reliance on testing systems that U.S. regulators may view as difficult to audit or exposed to national-security risk. The other is industrial: create demand for domestic laboratories and reward countries that open their own recognition systems to American providers.
A Federal Communications Commission building in Washington. Photo: Federal Communications Commission/Wikimedia Commons. U.S. government work in the public domain.
A Bottleneck With Real Costs
Relocating a compliance step is not as simple as changing an address. Laboratories need specialized equipment, trained personnel, accreditation and enough capacity to absorb new demand. Manufacturers may have to renegotiate contracts, retest products or redesign launch calendars around available facilities. The proposed December 2028 start date gives the market more than two years to adjust, but it also sets a deadline for building capacity that does not yet exist at the same scale.
Carr has paired the restriction with a promise of streamlined approval for devices tested in U.S. laboratories or in countries the agency regards as lower risk. Faster review could soften some of the added cost. Whether it does will depend on the final rules, the number of eligible facilities and how quickly the certification system handles a large geographic shift.
The burden is unlikely to fall evenly. Large manufacturers can spread testing across several regions and reserve laboratory time years ahead. Smaller hardware companies may have fewer options and less leverage. If eligible capacity tightens, they could face higher fees or slower entry into the U.S. market. That is an inference, not a stated outcome, but it is the practical pressure point regulators and industry will need to test before the vote.
Trust Is Infrastructure
The FCC’s proposal exposes a part of technology policy that usually remains invisible. Trust in a device is not created only by a rulebook. It is produced by laboratories, measurement standards, certification bodies, databases and the ability to audit the people who operate them.
Bringing more testing home may give U.S. regulators closer oversight and encourage new domestic investment. A broad reciprocity rule could also concentrate work in fewer places, raise costs and make international recognition more political. Both effects can be true at once.
The October 29 vote will therefore decide more than where a phone or computer is tested. It will define which institutions are allowed to certify technical trust for the American market, and how much of that trust the United States is willing to source from abroad.