The FCC Plans to End China-Based Testing: What It Means for Your Products

If your product has a radio in it (Wi-Fi, Bluetooth, cellular) or otherwise needs FCC certification, there's a good chance it was tested in a lab in China. That's about to change.

On October 29, 2026, the FCC votes on an order that would stop recognizing test labs and certification bodies in mainland China starting December 1, 2028. Labs in China tested about 82% of the devices that applied for FCC authorization in 2025, so this is one of the biggest shifts to US market access in years.

Two years sounds like plenty of time. It isn't, once you factor in product development cycles, lab capacity and the fact that many brands don't even know which lab their supplier used. Here's what's happening and what to do about it.

What the FCC Is Doing

This is the latest step in a series of FCC actions on test labs:

When	What happened
May 2025	"Bad labs" rules adopted: labs owned or controlled by foreign adversary governments lose FCC recognition (effective September 2025)
April 2026	FCC adds faster review for devices tested at trusted labs and starts the rulemaking on where testing can happen
October 29, 2026	Vote on the order limiting recognized labs and certification bodies to the US and economies with reciprocal testing agreements
December 1, 2028	Proposed date when labs in non-reciprocal economies, including mainland China, lose FCC recognition

The key shift is from who owns the lab to where the lab is. A lab owned by a Western company but located in mainland China would still be affected.

A few details from the draft order, as reported so far:

• Hong Kong and Taiwan labs are expected to remain recognized, because those economies have reciprocal agreements with the US.

• Existing grants stay valid. Equipment authorized before the cutoff doesn't need to be retested just because of this rule.

• Applications filed before the cutoff would be processed under the current rules.

• No waiver process for individual labs is planned in the draft.

  
  

The final order could change at the vote, so treat these details as provisional until the FCC publishes it.

Who It Affects

Any company selling products that need FCC certification in the US. That means anything with an intentional radio transmitter: phones, laptops, smart-home devices, wireless audio, networking gear, wearables and connected industrial or medical equipment.

What about products that only need an SDoC? Electronics with no radio, such as many audio products, effects units and power tools, are usually authorized under the FCC's Supplier's Declaration of Conformity (SDoC) instead of certification. SDoC testing doesn't have to be done at an FCC-recognized lab, so the draft order doesn't directly reach it, and in April 2026 the FCC chose not to require accredited labs for SDoC testing. Two cautions:

• Labs on the FCC's 2025 "bad labs" list, those owned or controlled by foreign adversary governments, can't be used for any FCC testing, including SDoC. Check your lab isn't on it.

• The FCC left the SDoC question open for comment, so the rules could tighten later. Confirm the final order after the vote.

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The scale is the real issue. In 2025, labs in China tested about 82% of devices applying for FCC authorization. US labs tested under 4%. Moving that much work will put pressure on lab capacity in the US and other recognized regions, and that usually means longer lead times and higher prices, especially as the 2028 date gets closer.

Three things make this easy to underestimate:

• You may not know where your product was tested. ODMs, contract manufacturers and wireless module suppliers often pick the lab, so the records may not be in your files.

• Making the product outside China isn't enough. A factory in Vietnam or Mexico may still send samples to a lab in Shenzhen.

• Lab ownership isn't the test anymore. A well-known Western lab brand can still have its testing done at a facility in mainland China.

  
  

What to Do Now

You don't need to retest anything today. But the companies that plan ahead will avoid the scramble for lab capacity in 2028.

1. Map your testing. For each product and wireless module, note whether it's authorized by certification or SDoC, then list the lab, its physical location and the certification body (TCB) that issued the grant. Ask your ODMs and module suppliers for this information too.

2. Look at your roadmap. Any product you'll be certifying in late 2027 or 2028 is the most at risk. Products that keep shipping on existing grants are fine, but new models and changes that need a new grant will need a recognized lab.

3. Qualify a backup lab now. Identify labs in the US or in reciprocal regions (Taiwan, Hong Kong, the EU, Japan, Korea and others) that can handle your test scope, and get a sense of their lead times and pricing.

4. Plan for sample logistics and cost. Testing farther from the factory means shipping samples, travel and possibly longer schedules. Build that into budgets and launch timelines.

5. Ask suppliers for a transition plan. Make it part of your supplier reviews: which labs they use today and what they plan to use after the cutoff.

6. Watch for the final order. Confirm the details after the October 29 vote, especially the transition rules for pending applications and changes to existing grants.

Need Help Planning the Transition?

We help hardware companies map where their products are tested, qualify new labs and plan certification schedules so launches stay on track. Book a free consult call to talk through your roadmap.

This article reflects the FCC's draft order as reported before the October 29, 2026 vote. We'll update it once the final order is published.

This article is for general information only and reflects requirements as of date of publish. It isn’t legal advice, and regulations change. Before making product or compliance decisions, confirm the current requirements with the relevant authority, a notified body, or a qualified professional.