A separate Federal Communications Commission proposal would materially expand the equipment-authorization framework governing communications devices sold or imported into the United States. The proposal addresses supply-chain transparency, Covered List exposure, and import volume limits for unauthorized devices.

The FCC is considering:

• Mandatory hardware and software bills of materials identifying component producers, production locations, and location-based value for FCC-authorized equipment;
• Disclosure of white-label manufacturers, brands, and models associated with a given FCC ID;
• Restrictions or presumptions against equipment containing components, software, or firmware from entities on the FCC's Covered List;
• Mandatory certification for routers, drones, and other devices in Covered List sectors;
• A requirement for a U.S.-based liable party for all FCC-certified equipment; and
• Registration requirements for devices currently using Supplier's Declarations of Conformity.

For covered equipment imported for testing or product development, the FCC proposes reducing the general unauthorized-device allowance from 4,000 units to 40 units, absent specific FCC approval. This represents a 99% reduction in the permissible import volume for pre-authorization testing.

The FCC is also considering requiring online marketplaces to verify—rather than merely display—FCC authorization information for listed products. This would shift compliance responsibility from passive display to active confirmation.

The proposal was filed for Federal Register publication on August 7, 2026. Comments are due 30 days after publication; reply comments are due 45 days after publication. Parties should verify exact dates against the published Federal Register notice before calculating deadlines.

For foreign electronics manufacturers and U.S. importers: Companies should immediately map component origin and manufacturing control across their supply chains. Products containing components from Covered List entities may face authorization restrictions or outright import bars under a final rule.

For private-label suppliers and OEM/ODM arrangements: Distribution and OEM agreements should be updated to require bills of materials, production-location disclosure, FCC-status warranties, change-of-supplier notifications, audit rights, and indemnification for authorization or import failures.

For online marketplaces: Platforms should assess their current FCC authorization display practices and evaluate the operational and legal implications of a verification mandate.

For technology distributors and importers engaged in pre-authorization testing: The proposed reduction from 4,000 to 40 units would significantly constrain product development timelines. Companies relying on the current allowance should evaluate whether to seek specific FCC approval or accelerate authorization processes.

The FCC document referenced above is a Federal Register public-inspection version scheduled for publication on August 7, 2026. The published version should be checked before calculating formal filing deadlines.

This update is prepared by ULF NEW YORK for informational purposes only and does not constitute legal advice. Readers should consult qualified counsel regarding specific transactions or compliance obligations.