Eleos Logo Eleos Compliance
Portal Contact
Public Regulatory Brief

Global Regulatory Intelligence

Verified compliance intelligence and regulatory updates curated by Eleos Compliance engineers.

Request Full Hub Access
United States of America Public Consultation Document In Force

Public Notice: U.S. Cyber Trust Mark Program Label Design, Certification Renewal, and Post-Market Surveillance

Affects: Certification Process Labelling Spectrum Management Testing

Last Updated

29-OCT-26

The FCC’s Public Safety and Homeland Security Bureau is seeking public comment on recommendations for the U.S. Cyber Trust Mark (USCTM) Program. The notice focuses on label requirements, certification renewals, post-market surveillance, and how the program will be administered.
Scope
The notice covers several areas:
  • Labelling: Requirements for label design, size, and placement on product packaging, websites, and documentation, as well as the information included in the “cyber nutrition” label.
  • Certification renewal: How and when manufacturers must renew their authorization to use the FCC IoT Label.
  • Post-market surveillance: How Cybersecurity Label Administrators (CLAs) will monitor certified products, select samples for testing, and address non-compliance.
  • Program administration: Procedures for the withdrawal or termination of the Lead Administrator or CLAs, including transferring records and handling complaints.
  • Regulatory impact: An Initial Regulatory Flexibility Analysis (IRFA) examining the potential impact on small businesses.
Key Technical Requirements
The FCC is considering several requirements, some of which are based on the CTA-2120 standard.
Label requirements
  • Physical labels would generally need to be at least 1 x 2 inches, although smaller alternatives are being considered.
  • The proposed minimum font size is 4 or 5 points.
  • Labels must include the Cyber Trust Mark and a scannable QR code linking to government-hosted information.
Cyber nutrition label
  • Information would be presented in two layers: a basic overview for consumers and more detailed information for technical users.
  • Manufacturers would need to disclose whether products contain cameras, microphones, or location-tracking sensors.
  • Manufacturers would also need to state whether they maintain a Hardware or Software Bill of Materials (HBOM/SBOM).
  • Information must be available in both English and Spanish.
Certification renewal
  • Certifications would need to be renewed every three years.
  • Renewal applications would require a test report from an accredited CyberLAB.
  • Testing would need to cover any new or revised requirements, along with 70% of the remaining requirements.
Post-market surveillance
  • CLAs would need to maintain a written Sample Test Plan and submit it annually to the Lead Administrator.
  • Surveillance testing must be carried out by a CLA-operated lab or recognized CyberLAB, rather than a manufacturer's in-house lab.
  • Manufacturers would have 30 days to provide production samples when requested. Failure to do so could result in certification being withdrawn.
Qualified Professional
  • Manufacturers holding certifications would need to appoint a Qualified Professional responsible for monitoring compliance and product changes.
  • This person would need to complete approved training and pass an exam covering USCTM Program requirements.

Attached Documents & Source Files

Public Notice: U.S. Cyber Trust Mark Program Label Design, Certification Renewal, and Post-Market Surveillance

Author / Agency: Federal Communications Commission

Published: 2026-10-27
Language: English

Key Regulatory Timeline & Dates

Dec 11, 2026
Commenting Deadline 45 days after publication in the Federal Register (Reply Comment Date)
Oct 27, 2026
Date Published Released: October 27, 2026
Nov 26, 2026
Commenting Deadline 30 days after publication in Federal Register

Stay Ahead of Global Regulatory Changes

Eleos Compliance delivers proactive regulatory monitoring, standard gap analysis, and type approval management across 150+ countries.