Early Commenters Advise Caution on FCC's Revised Lab Rules
The TCB Council urged the FCC to proceed with caution on new rules for telecommunications certification bodies (TCBs) in response to a May NPRM that was part of the agency’s focus on “bad labs” (see 2505220056). Initial comments are due Sept. 3 in docket 24-136, but some parties are filing early.
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“Changing the rules to require TCBs to audit filings that were granted by other TCBs could cause significant problems if it is not implemented correctly,” the council said in a filing Monday. “The proposed rules, if adopted, would still only authorize a TCB to request samples that they certified. Therefore, there would need to be a mechanism for a TCB to request samples they certified but then have those samples audited by other TCBs and their associated labs.”
The TCB Council also said “there may be some benefit to allowing any FCC-recognized lab to perform the surveillance testing, at the discretion of the manufacturer, which might require a modification of the FCC scheme requirements to not require a contract between the TCB and the surveillance test lab.”
Accreditation body A2LA said the FCC should consider a transition period “to allow for more laboratories to be accredited,” given that “a significant volume of testing laboratories are located within countries designated as foreign adversaries.” A2LA noted that the FCC estimates that 75% of all electronics are tested in labs located inside China. Shifting that testing to U.S.-based TCBs or those in mutual recognition agreement (MRA) countries “may take time, which will impact the import of electronic devices.”
The proposed rule won’t require that lab accreditation bodies be located only in the U.S. or MRA-partnered countries, A2LA said. “We concur with this action as it preserves reciprocal arrangements among MRA-partners while continuing to protect the integrity of the accreditation process for equipment authorization.” But the group said only U.S.-based and FCC-approved accreditation bodies should be allowed to perform assessments of test laboratories in non-MRA countries.