Norseman Projects
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US · FCC·10 min read·Paal Selnaes

The FCC rules have changed. The impact may be bigger than you expect.

Three recent FCC actions turn laboratory location, component provenance, and carrier access into design-review questions.

Note: This is an engineering and certification overview, not regulatory advice.

A small connected device circuit board on an RF test bench
Illustration (AI-generated).

Three questions, one filing

For years, a US filing asked one main question: does the product meet the technical rules? This autumn the Federal Communications Commission (FCC) added three more.

  • Where was it tested?
  • What is inside it?
  • Who connects it?

On 29 October the FCC adopted new test lab rules in a 3-0 vote (FCC 26-73). From 1 December 2028, an application must rely on testing done in the US or in a country on the FCC’s reciprocity list. Certifications granted before then stay valid.

A week earlier, the FCC blocked two devices because they contained a chip from HiSilicon, a Huawei subsidiary on its Covered List (FCC, 22 Oct). We covered that in The chip inside the module.

Three questions now sit between a working prototype and a US grant.

And on 30 October, the FCC accepted a consent decree with HKT, the Hong Kong carrier owned by PCCW. HKT will stop all its US services on or before 1 September 2027 (FCC DA-26-1163).

None of these is a new radio rule. They are three added constraints that can stop a product even when the radio meets the rules. Each one reaches the same place: the FCC grant. If your device connects to a carrier’s cellular network, PTCRB certification and carrier approval wait behind that grant too.

So the questions land in design review.

Here is what changed, why it matters, and what to check in the circuit design.

What changed

Where it was tested

The new order limits which test labs the FCC will recognise. A lab must sit in the US or in a “Reciprocal Economy”, a country with a mutual recognition or trade agreement with the US (FCC 26-73, ¶39 and Appendix D).

Why this matters: most FCC testing happens in countries that are not on the reciprocity list, above all China. China’s share rose from roughly 13% in 2007 to more than 82% by 2025, while the US share fell to less than 4% (3.6% in Chairman Carr’s statement) (FCC 26-73, ¶43).

Source: FCC 26-73, Statement of Chairman Carr; “rest of world” is the remainder.

China is not on the reciprocity list. So if your lab is there, your next US filing after 1 December 2028 needs a different lab.

The same limit covers Telecommunication Certification Bodies (TCBs) and the bodies that accredit labs (FCC news release).

The key points from the adopted text:

  • The date that counts is the application date. Applications received on or after 1 December 2028 fall under the new rules (¶39, ¶123).
  • Old grants stay valid. Grants and applications received before that date are not disturbed (¶39, ¶123).
  • Some details are still open. The FCC’s Office of Engineering and Technology (OET) will issue guidance on renewals and pending applications (¶123).
  • The list is broad, but not universal. It includes all EU member states, Norway, Iceland, Liechtenstein, the UK, Canada, Japan, South Korea, Taiwan and Hong Kong, among others. Mainland China, India and Switzerland are not on it (Appendix D).

A Further Notice of Proposed Rulemaking (FNPRM) means the rules may tighten again.

What is inside it

On 22 October the FCC blocked two devices because each contained a HiSilicon chip. The FCC calls it the first enforcement of its component rules, which took effect on 13 October and bar devices containing a logic-bearing component from a Covered List entity (FCC; The Verge).

We covered the detail in The chip inside the module. The short version: one logic-bearing part deep inside a module can now stop an otherwise compliant product.

One logic-bearing part deep inside a module can now stop an otherwise compliant product.

That is why you need to know your source. The part in your FCC test sample has to be the part in every production unit.

What we are seeing is remarked or relabelled chips, often from Asia, sold as genuine. A fake that works like the original breaks that chain silently, and it may bring in a Covered List or unvetted part. A dead fake is easier: it fails in production testing and never reaches the end user. And reliable checks, such as X-ray or decapping, only happen once the parts are already in house.

Who connects it

The third change is on the carrier side, not the device side. HKT and its PCCW subsidiaries agreed to leave the US market rather than contest the FCC’s move to revoke their authority (FCC DA-26-1163; Reuters via CNBC).

The decree sets two timelines (DA-26-1163, ¶11):

  1. Within 30 days, the companies must start the shutdown: file to discontinue domestic services and notify international customers.
  2. On or before 1 September 2027, they must stop all US services.

It does not touch any device’s FCC grant.

Why it matters for certification

The chain behind a US launch

Every radio product sold in the US needs FCC equipment authorization. If your device connects to a carrier’s cellular network, it usually passes two more gates, in order, and each one waits for the one before it.

Products without cellular, such as Wi-Fi, Bluetooth or LoRa devices, stop at the first gate. The lab and chip questions still hit them there.

  1. FCC equipment authorization. This is the legal requirement under 47 CFR 2.803 (47 CFR 2.803).
  2. PTCRB certification (cellular only). PTCRB requires the FCC ID before it issues certification (PTCRB PPMD v4.1, 11.3.1.8). Cellular IoT devices now go through a separate programme, IoT Network Certified (PPMD v4.1). It requires a PTCRB certified module.
  3. Carrier acceptance (cellular only). Each carrier runs its own process. AT&T uses IoT Network Certified, then its own onboarding. T-Mobile requires PTCRB first. Verizon runs its own certification and takes the FCC ID as an entry condition.
If the first gate moves, everything behind it moves with it.
  • A certified module does not authorize the host. A modular transmitter is approved with its antenna (47 CFR 15.212). FCC guidance says the host maker must still check emissions on the finished product, and a change of antenna type or gain can need a Class II permissive change, a change in FCC ID or a new FCC ID (FCC KDB 996369 D04).
  • Radiated tests come back on the host. For notebooks and tablets built on a certified module, PTCRB says the radiated RF part “must be retested” in all cases, including radiated spurious emissions (PTCRB PPMD v4.1, 11.11.10.4). IoT devices follow the IoT Network Certified guide instead, so check its host requirements for your product.
  • Antenna changes reopen testing. If the antenna changes after certification, the PTCRB lab decides which over the air (OTA) tests to repeat, or whether full OTA testing is needed (PPMD v4.1, 11.6.4).

A worked example (hypothetical)

This is an example, not a real product or customer.

Take a small battery powered cellular tracker that runs on a US carrier’s LTE-M network. It has an LTE-M cellular module, a GNSS receiver, a flex antenna and a European design team. The plan is a US launch in early 2029.

Gate 1: the FCC grant. Two of the three questions bite here.

  • Where was it tested? The team’s usual emissions lab sends some RF work to a sister site in a country that is not on the reciprocity list. After 1 December 2028, that data cannot support a new application. The team must retest at a listed lab.
  • What is inside it? A tracker without a camera seems safe. But the module’s own BOM includes a part the team has never checked. If it is a logic-bearing component from a Covered List entity, the filing is stopped.

Gate 2: PTCRB or IoT Network Certified. It applies because the tracker is cellular. A slip of three months at the FCC is a slip of three months here.

If the late retest came with a new antenna tune, expect radiated tests on the new design. The lab decides how much OTA testing to repeat.

Gate 3: carrier acceptance. The third question bites here.

  • Who connects it? The tracker uses a global eSIM profile from a roaming provider. If any part of that path relies on a carrier leaving the US, the service plan changes, and the carrier may ask for new data.

Add it up: a retest, a possible BOM change and a review of the service plan. The delays stack.

A Wi-Fi or Bluetooth version of the same tracker would stop after Gate 1. It would still face the lab and chip questions.

The point is timing.

What may come next (our view)

  • Labs will get busy. If most testing must move within two years, listed labs will fill up in 2027 and 2028.
  • OET guidance will set the edge cases. We expect clarification on whether pre-2028 test data can be reused for modifications or permissive changes filed after the transition date. The order leaves this to OET guidance (¶123). Until then, we would not plan on it.
  • Carriers may ask more questions about supply chains at onboarding. Nothing has been announced.
Each question is easy to answer in design review. Each one is expensive to answer after the filing.

How: what to check in the circuit design

The checks follow the order of a project, condition first.

Stage 1: design review

  1. If a module or chip is new to you, ask the vendor for the BOM of the module itself, not only the top level part number. Check its logic-bearing components against the Covered List before the BOM is locked. Then buy through authorised distribution, so the parts you checked are the parts you build with.
  2. If a part comes from a Covered List entity, replace it now. Swapping it after a refusal means a new circuit board and a new filing.
  3. If you plan a US filing in late 2028 or later, choose a lab in a listed country. Confirm where every step happens, including work sent to other sites.
  4. If the product is cellular and uses an eSIM or roaming provider, confirm who carries the traffic in the US and that the carrier holds its US authority.
  5. If the product shares a design with a European variant, note that a US variant filed after 1 December 2028 follows the new rules, even if its sibling was certified earlier.

Stage 2: circuit board spin

  1. If the antenna or its feed changes, treat it as an RF change. Expect the lab to ask for radiated and OTA retesting.
  2. If the flex layout changes near the antenna, check radiated performance again before you book the lab.
  3. If a power management part or charger changes, check conducted and radiated emissions again.
  4. If a module or chip is swapped for availability, run the Stage 1 check again and inspect incoming parts. A part bought outside authorised channels may not be the part you tested.
An engineer reviewing a parts list next to a circuit board
Illustration (AI-generated).

Stage 3: prescan

  1. If you have not prescanned emissions, do it before the formal lab slot. A failed formal test costs a slot.
  2. If ESD (electrostatic discharge) or interference fixes are likely, make them before formal testing.
  3. If prescan results are close to the limit, fix the margin now.

Stage 4: filing

  1. If the filing date could slip past 1 December 2028, confirm your test data still qualifies on the new date. The rule follows the date the application is received, not the ship date.
  2. If your TCB or lab is outside the US, confirm it appears on the FCC’s Reciprocal Economies list and keeps its recognition.
  3. If your device connects to a carrier’s cellular network, plan PTCRB or IoT Network Certified and carrier approval in sequence. None of them start before the FCC ID exists.
Book the lab early. Know what is inside every module. Know who carries the traffic.

The engineering has not changed. The timing has.

None of this asks for new radio skills.

What changed is when the three questions must be answered: in design review.

If you plan a US launch in the next two years, put all three on this quarter’s agenda.

Sources

  1. FCC 26-73, Third Report and Order and Third FNPRM, ET Docket 24-136, adopted 29 Oct 2026, released 30 Oct 2026: https://docs.fcc.gov/public/attachments/FCC-26-73A1.pdf (¶39, ¶123, Appendix D).
  2. FCC news release on FCC 26-73, 29 Oct 2026: https://docs.fcc.gov/public/attachments/DOC-426300A1.txt
  3. FCC DA-26-1163, HKT consent decree, 30 Oct 2026: https://docs.fcc.gov/public/attachments/DA-26-1163A1.txt (¶11).
  4. Reuters via CNBC, 31 Oct 2026: https://www.cnbc.com/2026/10/31/hong-kong-telecom-firm-agrees-to-halt-us-operations-under-pressure.html
  5. FCC news release on HiSilicon devices, 22 Oct 2026: https://docs.fcc.gov/public/attachments/DOC-426130A1.pdf
  6. The Verge, 22 Oct 2026: https://www.theverge.com/policy/1017016/fcc-block-foreign-surveillance-chips-hivision-huawei-loophole
  7. 47 CFR 15.212 (modular transmitters): https://www.ecfr.gov/current/title-47/part-15/section-15.212
  8. PTCRB Program Management Document v4.1, Dec 2025: https://www.ptcrb.com/wp-content/uploads/2025/12/PTCRB-PPMD-V4.1.pdf (opened 1 Nov 2026: 11.3.1.8 FCC ID before certification; 11.6.4 antenna changes; 11.11.10.4 radiated retest on notebooks and tablets built on a certified module).
  9. 47 CFR 2.803, marketing of radio frequency devices: https://www.ecfr.gov/current/title-47/part-2/section-2.803