Public Regulatory Brief
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United States of America
Regulation
In Force
Protecting Against National Security Threats to the Communications Supply Chain Through the Equipment Authorization Program
Affects:
Certification Process
Labelling
Spectrum Management
Testing
Executive Summary
The FCC amended its rules to prohibit the authorization of devices incorporating 'logic-bearing hardware components' produced by entities on the Covered List and to mandate that online marketplaces display FCC IDs for certified devices. Additionally, the rule restricts permissive changes for equipment produced by Covered List entities and clarifies definitions related to critical infrastructure.
Last Updated
23-SEP-26
The Federal Communications Commission (FCC) has introduced a final rule amending 47 CFR Parts 1 and 2. The aim of the rule is to strengthen the security of the communications supply chain and reduce risks linked to national security threats.
Scope
The new requirements apply to the authorisation, marketing and modification of radiofrequency devices. They particularly affect companies included on the FCC’s Covered List, as well as online marketplaces selling or advertising regulated equipment.
Key Technical Requirements
Logic-Bearing Hardware Components
Equipment authorisation will not be allowed where a device contains a "logic-bearing hardware component" manufactured by an entity on the FCC Covered List, if the complete device would have been prohibited had it been produced by that entity.
A logic-bearing hardware component can include a device, module, sub-assembly, system or integrated circuit that uses digital technology or radio frequency energy to process data. This generally includes components using timing signals above 9,000 cycles per second. Passive and purely mechanical components are not included.
Marketing and Online Marketplaces
Online marketplaces will be required to display a valid FCC ID for certified equipment at the point of sale.
Where a marketplace physically holds or owns the equipment, it must make sure that the FCC ID is displayed correctly. If the marketplace does not physically hold the equipment, it must verify that the FCC ID provided is valid and require the seller to confirm that the information is accurate.
Some listings are exempt from these requirements, including certain existing listings that have not been changed, listings from sellers who are not classed as high-volume third-party sellers, and listings for used equipment.
Modifications and Recertification
Entities included on the Covered List will no longer be allowed to use permissive change procedures or the Supplier’s Declaration of Conformity (SDoC) process when making changes to equipment. Instead, modified equipment will need to go through a new certification application.
This also applies where a proposed change would make equipment prohibited. For example, this could happen if production of a device is moved to a manufacturer that appears on the Covered List.
Critical Infrastructure
The FCC has also updated its definition of critical infrastructure so that it is more closely aligned with 42 U.S.C. 5195c(e). This covers systems and assets that are essential to the United States and where disruption or failure could seriously affect national security, economic security, public health or safety. The definition is linked to 16 critical infrastructure sectors and 55 National Critical Functions.
The rules are due to take effect on 13 October 2026. The FCC ID requirements for online marketplaces have later compliance dates, with requirements being introduced from 1 March 2027 and 1 June 2027, depending on the type of marketplace or seller.
Attached Documents & Source Files
FCC Third Report and Order (FCC 26-50)
Author / Agency: Federal Communications Commission
Key Regulatory Timeline & Dates
Jun 01, 2027
Compliance Deadline
Deadline for online marketplaces relying on third-party seller certifications to display FCC ID.
Oct 13, 2026
Date of Entry into Force
General effective date for the final rule.
Mar 01, 2027
Compliance Deadline
Deadline for online marketplaces with physical access to or title over the device to display FCC ID.
Sep 11, 2026
Date Published
As stated in the Federal Register publication.
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