If you still understand U.S. FCC certification solely as “Electromagnetic Compatibility testing”, your knowledge may be outdated by two years. Between 2024 and 2025, the FCC’s regulatory logic underwent a quiet yet profound shift: from pure technical performance oversight to a “frontline reviewer” of national communication network security and supply chain risks. This means the challenge of entering the U.S. market has shifted from the laboratory test bench to the enterprise’s shareholder register and global supply chain map.

I. Core Shift of FCC Certification: From “Technical Compliance” to “Security Compliance”

In the past, the core of FCC certification was answering: “Will this device interfere with other devices during operation?” Now, it must first answer two new questions:

1.“Who is certifying this device?” — Does it involve entities with unacceptable security risks?

2.“Could this device itself become a network vulnerability?” — Could it endanger U.S. communication infrastructure?

This shift was realized through the implementation of several landmark rules, which together form an increasingly tight “security filter”.

  II. Key Update 1: “Security Ban” on Testing and Certification Qualifications

This is the most far-reaching update, directly changing the qualifications of participants in the game.

1. New Rules on Equipment Authorization Program Security and Integrity (Released April 2024, Fully Effective September 2025)

·Core Content: The FCC explicitly prohibits its recognized Telecommunication Certification Bodies (TCBs) and testing laboratories from conducting device certification or testing for any client directly or indirectly owned or controlled by 10% or more by entities on the so-called “Covered List”.

·In-depth Implication: This is not a simple market restriction. It means the FCC has frontloaded and outsourced its national security review obligations to all third-party certification bodies. TCBs and laboratories must now perform thorough due diligence to verify the client’s equity structure.

Impact on Enterprises:

·Directly Affiliated Enterprises: Enterprises explicitly listed and their subsidiaries can hardly obtain FCC ID certification through formal channels.

·Indirectly Affiliated Enterprises: If the supply chain (e.g., key chip or module suppliers) or shareholder structure involves “Covered List” entities, and the 10% threshold is met, the certification application will face extremely high risks. Enterprises must be prepared to provide TCBs with clear equity certificates and supply chain declarations.

2. Dynamic Expansion of the “Covered List”

·This list is not static. The FCC has the authority to continuously update it in accordance with executive orders and congressional requirements. In 2025, the industry closely watches whether more Chinese technology enterprises will be included.

·Response Strategy: Exporters must establish a dynamic monitoring mechanism, paying attention not only to FCC rules but also to updates such as the U.S. Department of Commerce BIS’s “Entity List”, as adjustments to the “Covered List” are often linked to it.

  III. Key Update 2: Refinement and Strengthening of Technical Rules

While tightening security controls, the FCC has simultaneously raised technical standard requirements.

1. Implementation of 100% Hearing Aid Compatibility (HAC) Mandatory Timeline

-New Rule: The FCC has clarified the final deadline for wireless handheld devices (mainly mobile phones) to achieve 100% compatibility with hearing aids.

-Key Milestones:

·December 14, 2026: A rigid watershed. After this date, newly certified or significantly modified devices must 100% meet HAC standards in three dimensions: acoustic coupling, radio frequency interference, and inductive coupling (T-Coil).

·Bluetooth Protocol Transition Period: From December 14, 2026 to December 13, 2028, proprietary or universal Bluetooth protocols are allowed; after December 13, 2028, only universal Bluetooth protocols based on low-power audio are permitted for compatibility.

-Impact: This requires mobile phone manufacturers to integrate HAC solutions from the initial product design stage and plan the evolution path of Bluetooth audio technology.

2. Refinement of 6GHz Band Rules (Core Band for Wi-Fi 6E/7)

·With the surge in Wi-Fi 6E/7 devices, the FCC continues to improve the usage rules for the 6GHz band (5925-7125 MHz).

·Focus: More refined testing requirements for transmission power, frequency bands, and Automatic Frequency Coordination (AFC) system compliance of Low Power Indoor (LPI) and Standard Power (SP) devices. Incorrect classification or incomplete testing is a common cause of current certification failures.

3. Cybersecurity and Device Authorization

·Although the FCC has not yet introduced a unified cybersecurity authorization standard like the EU RED Directive, it has shown high attention to cybersecurity vulnerabilities in connected devices (especially IoT devices) through public consultations and cases. Devices with known and unpatched critical security vulnerabilities may face delisting risks.

  IV. Key Update 3: Targeted Rules for Key Product Categories

1. IoT Devices Become the Focus

·With the advancement of the 2024 IoT Device Security Labeling Program, consumer IoT devices such as smart cameras, routers, and doorbells may need to display a cybersecurity rating label similar to “Energy Star” on their physical packaging in the future. Although the program is currently voluntary, it paves the way for mandatory regulation.

2. Drones and Radio Equipment

·The FCC has strengthened regulation of radio equipment used in drone systems, requiring their radio frequency parameters to strictly comply with rules and ensuring no harmful interference to key communication bands.

  V. 2025 Enterprise Compliance Upgrade Roadmap

Facing the new rules, enterprises must upgrade their response strategies:

1. Step 1: “Penetrating” Self-Inspection of Supply Chain and Equity

·Conduct a thorough self-inspection before launching any certification project: check whether key component suppliers, technical partners, and even major shareholders have connections with “Covered List” entities. This is a necessary upfront cost.

2. Step 2: Cautiously Select Compliance Partners

·When choosing TCBs and laboratories, proactively inquire about their due diligence processes for the new rules. Prioritize institutions with rich experience and transparent processes in this regard, as they can better guide you in preparing the required legal and certification documents.

3. Step 3: Technical Forecasting and Advance Layout

·Mobile Phone Manufacturers: Immediately assess the compliance of product lines with 100% HAC requirements and plan Bluetooth protocol solutions.

·Wireless Product Manufacturers: Closely monitor subtle adjustments to rules for bands such as 6GHz and 5G, and adopt designs that meet the latest standards during the R&D phase.

·All Connected Device Manufacturers: Integrate cybersecurity into product lifecycle management and establish a vulnerability response mechanism.

4. Step 4: Expand Document Preparation from “Technical Proof” to “Security Statements”

·Technical documents may need to add non-technical documents such as “Supply Chain Security Statements” or “Equity Structure Explanations” to respond to TCB reviews.

The wave of FCC certification updates essentially embeds “risk management” in major power technological competition into the technical rule processes of global trade. It is no longer just a “technical action” completed by engineers, but a “risk control action” requiring the joint participation of legal, risk control, and strategic departments. For Chinese enterprises, understanding and adapting to this new logic is not only about obtaining a market access certificate but also about proving their reliability and transparency in the restructuring of the global supply chain.

BLUEASIA Technology: +86 13534225140 provides professional certification consulting services.