FCC Plans to Drop China Test Labs by 2028: A QC Plan for Electronics Importers
The FCC votes October 29 on ending recognition of test labs in mainland China. Here is what the draft says, which grants stay valid, and how to build the lab question into your QC program.
In this piece 8 sections
The Federal Communications Commission will vote on October 29, 2026 on a draft order that would end recognition of China test labs for FCC equipment authorization. Under the draft, labs in mainland China lose recognition on December 1, 2028. Existing grants stay valid. New wireless and electronic products would need testing in the US or a reciprocal economy.
Most importers of electronics never think about the lab. The factory sends an FCC ID, the product ships, and nobody asks where the radio was tested. That habit is about to get expensive. According to FCC Chairman Brendan Carr, less than 4% of electronic devices are tested in labs located inside the US.
Eastern Plays covers sourcing and quality control for Western businesses buying from Asia. This explainer is for importers of anything with a radio or a circuit board: Bluetooth speakers, smart plugs, chargers, LED lighting and small appliances. It covers what the FCC is proposing, the dates that matter, and a practical plan for your testing and QC program.
What Is the FCC Proposing for China Test Labs?
The FCC proposes to stop recognizing test labs and certification bodies in economies that lack a mutual recognition agreement or reciprocal trade deal with the US. Mainland China is not on the reciprocal list. If adopted, China test labs could not support new FCC equipment authorizations after December 1, 2028.
The idea did not appear overnight. In May 2026 the FCC published a Federal Register proposal to stop recognizing labs in non-reciprocal economies. It asked whether to use a hard cutoff, a phase-out at renewal, or an extra fee as high as $20,000 on applications tested in those labs.
The October draft picked the hard cutoff, with roughly two years of runway. Industry groups, including the Consumer Technology Association, had asked for three to five years. China's WTO technical barriers enquiry point also objected, calling the rule discriminatory.
Which Products Need FCC Equipment Authorization?
Equipment authorization is the FCC approval a device needs before it can be marketed in the US. It covers anything that emits radio frequency energy. That includes obvious radios like Wi-Fi and Bluetooth gear, and less obvious items like LED drivers, power supplies and digital toys.
There are two main routes. Certification is the stricter path and applies to intentional transmitters, such as a wireless earbud or a smart plug. A recognized lab tests the device, and a Telecommunications Certification Body (TCB) reviews the report and issues a grant tied to an FCC ID. The draft order targets both of those players.
The lighter route is the Supplier's Declaration of Conformity (SDoC). It is used for many devices without a deliberate radio, like a basic LED lamp. The responsible party in the US keeps the test records. How the final order treats SDoC testing is worth confirming with your lab once the text is out.
The practical split for most importers is simple. If your product has a wireless feature, it almost certainly goes through certification, and it is in scope.
Why China Test Labs Matter to Your Supply Chain
The scale is the whole story. DroneXL's breakdown of the draft FCC order says labs in China tested 82% of the devices that applied for FCC authorization in 2025. In 2007, Chinese labs handled about 13% and US labs about 31%. Of the 609 FCC-recognized labs, about a quarter sit in China.
That share exists because testing near the factory is cheap and fast. An engineer can walk a sample from the production floor to the lab in an afternoon. Moving that testing elsewhere adds shipping time for samples, higher fees and more back-and-forth on failures.
The FCC has been tightening the system for more than a year. A Reuters report on the planned FCC vote notes that the agency barred dozens of labs owned or controlled by the Chinese government in 2025. The new draft goes further, because it is based on location, not ownership.
Key Dates for China Test Labs and FCC Grants
Most of the near-term dates are procedural, but they set the planning window. The table below lists the ones an importer should put on a calendar.
| Date | What happens | What it means for importers |
|---|---|---|
| May 15, 2026 | FCC proposal on non-reciprocal labs published | The policy direction became public |
| June 15, 2026 | Trusted Test Lab fast-track rule takes effect | Faster review for some devices tested in trusted labs |
| October 29, 2026 | FCC open meeting vote on the draft order | Final text may change dates or scope |
| December 1, 2028 | Draft cutoff for labs in mainland China | New grants need US or reciprocal-economy testing |
The draft protects what you already have. Grants issued before the cutoff remain valid, and applications filed before it are processed under the old rules. The risk sits with new products and with redesigns that need a new grant after 2028.
One caveat matters a lot. This is a draft until the vote. Commissioners can change the cutoff date or the list of eligible economies, so check the final order before you change suppliers or labs.
How the FCC Fast Track for Trusted Labs Works
The FCC has already created an incentive to move testing. Its final rule creating a fast-track review for trusted test labs took effect on June 15, 2026. It gives priority review to devices that need Pre-Approval Guidance (PAG) when they are tested in a Trusted Test Lab.
Pre-Approval Guidance is the extra FCC sign-off step required for certain complex or novel devices before a certification body can issue a grant. Those products tend to have the longest approval queues. Products with more complex radios often fall into this group, so the fast track can matter more than the fee difference between labs.
The same rule also tightened post-market surveillance. That means more devices pulled from the market and retested after approval. A grant built on weak test data is now a bigger liability than it was two years ago.
A QC Plan for Electronics Importers Before 2028
Treat lab location as a supplier qualification question, not a paperwork detail. Eastern Plays' editors suggest working through these steps in order:
- List every SKU with an FCC ID, and note the grantee and the lab named in the test report.
- Flag products you expect to redesign, refresh or launch after mid-2028.
- Ask each factory which recognized labs outside mainland China they already use.
- Get quotes from a lab in Hong Kong, Taiwan, Vietnam or the US for one representative product.
- Write the lab requirement into new purchase orders and supplier quality agreements.
- Keep the test report and grant on file for every SKU, not just the factory's word.
Budget is the next question. Ask for lab quotes now, while labs outside China still have spare capacity. A quote today is a planning number, not a commitment, and it shows how much a move would add per SKU.
Step six sounds basic, but it catches real problems. In June 2026 the FCC found 33 incorrect or false test reports from one Dongguan lab. If a factory reused a report from a different model, your inspector would never know without the file.
Pre-shipment inspections can do part of this check. Ask your inspector to photograph the FCC label and match the FCC ID to the grant on file. If you use an in-country team, our guide on paying a sourcing agent or QC inspector in Asia covers the practical setup. If you also import children's electronics, line this up with the CPSC eFiling test data your factory must supply.
Will Moving Testing Out of China Raise Costs?
Almost certainly, at least at first. US lab capacity is small compared with demand, and the shift will push more work into labs in Taiwan, Hong Kong and Southeast Asia. Expect longer queues there as 2028 approaches, especially for complex wireless products.
The counterargument is fair. Supporters say a lab in a reciprocal economy is easier to audit, and fewer bad reports mean fewer surprise recalls. For a small importer, though, a delayed grant still means a delayed launch.
This sits alongside other China-related supply chain checks. If you are already screening factories for forced-labor risk, our walkthrough of checking China suppliers against the UFLPA Entity List fits the same supplier file.
What to Do Now
Do not panic, and do not switch labs before the final vote. The draft keeps existing grants valid and gives about two years of runway. What you can do now is map which products depend on China test labs and which ones will need new grants after 2028.
We've seen importers lose a season because one approval stalled. Building the lab question into supplier agreements now is cheap. Doing it in late 2028, with every other importer, will not be.
