Before a smartphone is listed in the United States, the manufacturer must obtain the results of radio frequency, interference and equipment compliance tests. The location where these tests were completed is not necessarily in the United States. According to data disclosed by Brendan Carl, Chairman of the United States Federal Communications Commission (FCC), about 82 per cent of the tests that entered the United States equipment certification process in 2025 were completed in China and less than 4 per cent of the United States.

This ratio has made China's testing service the main target of the new US TSS. On October 29, the FCC will vote on a rule to extend the scope of laboratory restrictions: no longer exclude only those institutions owned, controlled or controlled by the Chinese Government, but also to de-eligate laboratories and associated certification bodies from countries that have not established reciprocal accreditation arrangements with the United States. Lutherans quoted Reuters on 8 October to report this development. This is a re-establishment of a system around “who is qualified to certify that electronics are in line with United States regulations”, far more than just the import of a tungsten, agile or a certain type of terminal equipment.

原始来源 · reuters.comReuters:FCC将于10月29日表决扩大中国实验室禁令reuters.com ↗

See first the number: 82% exactly what it means to be a person.

The 82 per cent statement by the FCC, which relates to the distribution of detection sites in its equipment authorization process, cannot be interpreted as directly “82 per cent of electronic products in the United States market are manufactured in China” or as being under government command for all laboratories in China. Equipment can be designed in one country, manufactured in another country and completed by a third-site laboratory for electromagnetic compatibility or radio frequency testing. The location of the test, the origin of the product and the legal identity of the certification body are three different indicators.

FCC主席布伦丹·卡尔,资料照|来源:CES
FCC主席布伦丹·卡尔,资料照|来源:CES · 查看图片来源 ↗

This difference is precisely a sign of where the policy shock may have been. The United States controls whether terminals meet national communications standards, but a significant number of the chain of production of evidence for compliance has been concentrated outside the country. The resulting dependency does not automatically disappear because the product eventually has a United States authentication mark on it. Testing the authenticity of archives, laboratory independence and the ability of regulatory bodies to track unusual data are key to determining the credibility of the access system.

Old prohibitions are underlined by control relationships and new rules are underlined by State mutual recognition of qualifications

In 2025, the FCC first imposed restrictions on testing laboratories owned or controlled by foreign opponents. Its 2026 official document states that 23 laboratories, including a number of Chinese testing agencies, were no longer accredited as a result. The key change in this expansion was to move from a home-by-house survey of “who controls laboratories” to a decision on access based on the existence of mutually acceptable testing institutions between countries.

This shift involves the cost of regulatory design. Individual surveys can be more precise in targeting risk institutions, but regulators need to invest resources to identify equity and control relationships on a continuous basis; The routing of agreements to host countries and reciprocity is easier to implement and may also affect a large number of private testing agencies without record of non-compliance. While United States regulators emphasize national security and fairness and reciprocity, Chinese enterprises face the cost of re-engineering testing operations. The test that policy should be met is whether it improves the credibility of compliance testing or simply transfers it to other countries with higher fees and unestablished capacity.

原始来源 · docs.fcc.govFCC4月政策说明:互惠原则与两年过渡期docs.fcc.gov ↗

Regulatory risk is not a fiction. In June this year, the FCC publicly alleged that a testing laboratory in Dong-hoon had submitted the same results for different equipment and that it had initiated the disqualification procedure accordingly. The regulatory document states that the material involved involves 33 FCC identification numbers. The forgery of the test reports is a regulatory failure that can be verified in a specific way; However, it cannot be inferred from this that all Chinese testing agencies are falsifying reports. Regulatory bodies have chosen to overhaul access rules and must face the extent of evidence between them.

The ban has not yet entered into force, but the restructuring of the enterprise cannot wait until 2028

According to the current timetable, 29 October will be the first date for the CFC to vote on the new rules; The proposed restrictions are scheduled to enter into force on 1 December

  1. At this stage, there is no fait accompli that Chinese laboratories are banned by the new rules in their entirety. Reuters reported that the new programme also considered expediting the approval process for United States laboratories and national laboratories with a defined low-risk, reciprocal arrangement.

The costs to the manufacturer are not just to relocate a sample location. The continued use of test reports, how the transitional equipment model is applied, the appointment cycle of laboratories in different countries and the adequacy of test capabilities will affect the listing schedule of products. Small and medium-sized manufacturers may have more difficulty in bearing the burden of re-engineering test routes than large TNCs.

The problem ultimately reverts to the long-encouraged industrial concentration and certification market advantage in Beijing: when a country ' s manufacturing, supply chain and compliance services accumulate to the extent that the United States market is highly dependent, geopolitical risks no longer exist only in the final product. The United States has chosen to advance its national security judgement to “where the certificate of compliance comes from”. For the Chinese detection industry, technological capabilities and the size of the business are no longer sufficient to guarantee market access, and cross-border regulatory trust becomes a new competitive ticket.

For Beijing, the shock revealed that state-led manufacturing scale is not the same advantage as trust in transnational markets: China can concentrate on a large number of detection facilities, but cannot require that offshore regulators permanently recognize their independence. Changes in the United States system will force businesses to pay additional compliance costs for the vague control border between government and business, which will eventually be passed on to producers and consumers.

原始来源 · federalregister.gov美国《联邦公报》:FCC 26-28规则征求意见稿及法律适用范围federalregister.gov ↗
SGS电磁兼容实验室资料图,非涉事中国实验室
SGS电磁兼容实验室资料图,非涉事中国实验室 · 查看图片来源 ↗
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