QAI can help you understand what this means for your next filing.

If you are relying on a TCB that is no longer recognized for the next grant of your wireless radio, the risk is not usually to the product you already sell. It is to the one you are about to file. QAI is an FCC recognized EMC test laboratory and Telecommunication Certification Body, with laboratories in Canada and the United States.

What the FCC changed

In May 2025 the FCC adopted rules, commonly referred to as the “Reciprocal Rule”. The FCC Looks to Prohibit Electronic Device Testing Using Labs in Countries Without Reciprocal Agreements . It proposes to prohibit device testing labs and certification bodies in foreign countries that have not signed reciprocity agreement to recognize American test labs and certification bodies. Also it prohibits recognition of any test laboratory, Telecommunication Certification Body (TCB), or laboratory accreditation body that is owned by, controlled by, or subject to the direction of an entity the U.S. government has identified as a foreign adversary. The prohibition follows ownership and control, not geography, so it applies regardless of where a laboratory is physically located.

Enforcement began in September 2025, when the FCC’s Office of Engineering and Technology initiated proceedings involving an initial group of foreign EMC and RF testing laboratories and certification bodies. The Commission has since taken additional actions, and 23 test laboratories identified as being controlled by prohibited foreign entities have had their recognition withdrawn, denied, or otherwise affected.

For manufacturers, the practical effect is straightforward: a laboratory that could support an FCC filing previously may no longer be recognized for future testing or equipment authorization work.

Official FCC Information

Does this affect a product you already sell?

In general, no. These rules govern which laboratories the FCC recognizes. They do not revoke equipment authorizations that have already been granted. If your product holds a valid FCC ID today, it keeps it.

The exposure sits somewhere else. Consider your position if any of the following apply:

• You have an application in progress that is supported by test data from a laboratory whose recognition has since been withdrawn.
• You plan to file a permissive change, a new variant, or a family addition under an existing FCC ID, using the original test data as the basis.
• You started a test program at a laboratory and did not complete it before the withdrawal took effect.
• Your product is covered by a separate FCC Covered List action, which operates independently of these laboratory rules.

If you are not certain which of these describes your situation, confirm it before you file, not after. A rejected application costs more time than a file review.

Five steps if your laboratory is on the list

1. Find out who did the testing. The laboratory name is on the cover page of your test report and in the grant file attached to your FCC ID.
2. Check that laboratory’s current status. The FCC publishes a list of recognized accredited test laboratories. A laboratory that appeared on it last year may not appear on it today.
3. Separate what is closed from what is open. Granted and shipping is one category. In progress, planned, and about to be modified is another. Only the second category is at risk.
4. Decide what needs retesting and what needs a document review. Not every open item requires a full retest. Some need a compliance file review and a fresh report against the current standard.
5. Choose a laboratory that will still be recognized at the end of your program. Certification timelines run months. Pick for where the rules are going, not only where they are today.

How QAI can help

QAI performs the testing and issues the certification. You deal with one organization from the first sample to the approval.

Our EMC laboratory is accredited by A2LA to ISO/IEC 17025 and is registered with the FCC and with Innovation, Science and Economic Development (ISED) Canada. QAI is an FCC recognized Telecommunication Certification Body, a Certification Body for Canada under ISED, and a Notified Body for the European Union. QAI also holds accreditations by the Standards Council of Canada (SCC) as a certification body and is recognized by OSHA as a Nationally Recognized Testing Laboratory (NRTL) for specific applications.

Our testing is performed at our own laboratories in Canada and the United States. Our EMC laboratory holds three semi anechoic chambers and a 10 m open area test site, so a transferred program does not get queued behind a subcontracted facility.

Capabilities relevant to a transferred program:

• RF emissions and immunity across three semi anechoic chambers and a 10 m open area test site (OATS)
• Wireless and radio certification, including 5G, up to 300 GHz
• Military and defense testing to MIL-STD-461G, including CE, CS, RE and RS
• Medical electrical equipment, automotive, marine, avionics, telecommunications, information technology, industrial and consumer products
• FCC, ISED and CE certification handled in the same program
• Compliance file review for programs that started elsewhere